Advanced Correctional Healthcare, Inc., Minnesota Sheriff's Association, Becker ...

Court of Appeals of Minnesota·Decided June 15, 2026·No. a251685·Unpublished

Opinion

This opinion is nonprecedential except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA

IN COURT OF APPEALS

A25-1685

Advanced Correctional Healthcare, Inc., et al., Appellants,

Minnesota Sheriff’s Association, et al, Appellants,

Becker County, et al.,

Appellants,

St. Louis County,

Appellant,

Steele County,

Appellant,

vs.

Paul Schnell,

Respondent.

Filed June 15, 2026

Affirmed

Bratvold, Judge

Ramsey County District Court File No. 62-CV-25-5225

Sarah M. Hoffman, Bassford Remele, P.A., Minneapolis, Minnesota; and

Peter R. Jennetten (pro hac vice), Quinn Johnston, Peoria, Illinois (for appellants Advanced Correctional Healthcare, Inc., et al.)

Richard D. Hodsdon, Stillwater, Minnesota (for appellants Minnesota Sheriffs’ Association, et al.)

Brian W. McDonald, Becker County Attorney, Detroit Lakes, Minnesota (for appellants Becker County, et al.)

Kimberly J. Maki, St. Louis County Attorney, Nick D. Campanario, Assistant County Attorney, Duluth, Minnesota (for appellant St. Louis County)

Robert J. Jarrett, Steele County Attorney, Owatonna, Minnesota (for appellant Steele County)

Keith Ellison, Attorney General, Kevin M. Jonassen, Christy L. Hall, Assistant Attorneys General, St. Paul, Minnesota (for respondent)

Considered and decided by Bratvold, Presiding Judge; Ross, Judge; and Reilly, Judge. * NONPRECEDENTIAL OPINION

BRATVOLD, Judge Appellants are individuals, corporations, and government entities responsible for providing medical care to incarcerated persons in correctional facilities. Appellants sued to challenge the constitutionality of recently enacted Minnesota Statutes section 241.021, subdivision 4f (Supp. 2025), which governs the licensing and supervision of correctional facilities under the authority of the Minnesota Department of Corrections (DOC). Subdivision 4f(a) requires licensed correctional facilities to administer “the same medications” prescribed to incarcerated persons before their incarceration. Appellants received a temporary restraining order (TRO) by stipulation among the parties and moved for a temporary injunction to block enforcement of the statute during the lawsuit. The

*

Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to Minn. Const. art. VI, § 10.

district court denied the temporary injunction and dissolved the TRO, and this interlocutory appeal follows. We affirm.

FACTS

In May 2025, the legislature amended Minnesota Statutes section 241.021 and adopted subdivision 4f: “Correctional facilities licensed by the commissioner shall administer to confined and incarcerated persons the same medications prescribed to those individuals prior to their confinement or incarceration.” Minn. Stat. § 241.021, subd. 4f(a); see also 2025 Minn. Laws ch. 35, art. 5, § 6, at 694. Subdivision 4f(b) has three exceptions, 1 providing that subdivision 4f does not apply when

(1) a licensed health care professional determines, after consulting with the licensed health care professional who prescribed the medication, that the prescribed medication is not medically appropriate for the person based on the person’s medical condition or status;

(2) a licensed health care professional determines a medication that is at least as effective as the current medication the person is prescribed is available to treat the condition and the licensed health care professional who prescribed the current medication approves the change in medications; or (3) the person provides written notice to the licensed health care professional who is responsible for inmate health

1 Subdivision 4f(b) includes prefatory language stating that these exceptions do not apply to “a confined or incarcerated person who is subject to a Jarvis order that dictates otherwise.” A Jarvis order authorizes the involuntary administration of neuroleptic medication. See Jarvis v. Levine, 418 N.W.2d 139, 150 (Minn. 1988). Neuroleptic medication is used for “sedation of the nervous system”; the term may be used interchangeably with “antipsychotic” medication. Id. at 140 n.1.

care at the correctional facility that the person no longer desires to take the medication.

Minn. Stat. § 241.021, subd. 4f(b). 2 Because subdivision 4f and its exceptions were adopted as part of an appropriations bill, they became effective on July 1, 2025. 3 Before subdivision 4f took effect, appellants filed a complaint seeking a permanent injunction to block respondent Paul Schnell, in his official capacity as Minnesota Commissioner of Corrections, from enforcing subdivision 4f and further requesting declaratory-judgment relief as described below. Appellants are: three corporations that provide medical services or medical staffing to Minnesota county jails; four individual medical providers who are employed by one of the appellant corporations, including two physicians and two certified nurse practitioners; thirteen Minnesota counties; five county sheriffs; and the Minnesota Sheriffs’ Association (MSA).

The amended complaint alleges three claims for declaratory-judgment relief under the Minnesota Uniform Declaratory Judgments Act, Minnesota Statutes sections 555.01-.16 (2024). Each claim incorporates the allegation that subdivision 4f

2 The legislature recently enacted revisions to subdivision 4f effective August 1, 2026. 2026 Minn. Laws, ch. 97, art. 4, § 1; Minn. Stat. § 645.02 (2024) (“Each act, except one making appropriations, enacted finally at any session of the legislature takes effect on August 1 next following its final enactment, unless a different date is specified in the act.”). The 2026 amendment is not before us in this appeal, and we consider only the 2025 version of subdivision 4f. 3 “An appropriation act or an act having appropriation items enacted finally at any session of the legislature takes effect at the beginning of the first day of July next following its final enactment, unless a different date is specified in the act.” Minn. Stat. § 645.02; see 2025 Minn. Laws, ch. 35, arts. 1-2 (setting appropriations for the judiciary and public safety), 5, § 7, at 694 (adding subdivision 4f to section 241.021).

“mandates the administration of medication that could be harmful or fatal to inmates who are in the custody” of correctional facilities that are subject to the statute.

Count 1 alleges that subdivision 4f compels appellants to provide medical care that may violate inmates’ rights under the Eighth and Fourteenth Amendments to the U.S. Constitution and article I, section 5 of the Minnesota Constitution and that subdivision 4f prevents appellants “from complying with their obligations to provide care that complies” with these constitutional rights. Count 2 alleges that subdivision 4f violates the liberty and property rights of the corporate and individual medical-provider appellants under the Fourteenth Amendment by compelling them to violate their professional obligations in order to comply with state and federal law. Count 3 alleges that subdivision 4f would compel the individual medical-provider appellants to violate professional standards in the Minnesota Medical Practice Act and the Minnesota Nurse Practice Act. For each count, appellants seek a declaratory judgment that subdivision 4f is unconstitutional or unlawful and a permanent injunction against its enforcement.

Appellants moved for a temporary injunction to block enforcement of subdivision 4f during the lawsuit. Four days later, the parties stipulated to entry of a TRO to enjoin enforcement of subdivision 4f until August 1, 2025. The district court filed a TRO “in effect until August 1, 2025, unless extended or rescinded by Order of the Court.” The district court later extended the TRO until it ruled on appellants’ motion for temporary injunctive relief. Respondent opposed the motion for a temporary injunction.

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