Chad Loran Siegel v. Drew Evans

Supreme Court of Minnesota·Decided August 19, 2026·No. A240594·Published

Opinion

STATE OF MINNESOTA

IN SUPREME COURT

A24-0594

Court of Appeals Thissen, J.

Concurring in part, dissenting in part, McKeig, Moore, III, JJ.

Chad Loran Siegel, Appellant,

vs. Filed: August 19, 2026 Office of Appellate Courts Drew Evans,

Respondent.

Bradford Colbert, Legal Assistance to Minnesota Prisoners, Saint Paul, Minnesota, for appellant.

Keith Ellison, Attorney General, Angela Helseth Kiese, Assistant Attorney General, Saint Paul, Minnesota, for respondent.

Cathryn Middlebrook, Chief Appellate Public Defender, William Ward, Minnesota State Public Defender, Saint Paul, Minnesota, for amicus curiae Minnesota Board of Public Defense.

SYLLABUS

Requiring a person to register as a predatory offender under Minnesota Statutes section 243.166, subdivision 1b(a)(1), based on a predatory offense for which the person was charged but subsequently acquitted by the district court’s entry of a judgment of

acquittal at trial violates that person’s substantive due process rights under the Minnesota Constitution.

Reversed and remanded.

OPINION

THISSEN, Justice.

Minnesota’s predatory-offender-registration statute, Minnesota Statutes section 243.166, subdivision 1b(a)(1), provides that a person who has been “charged with” one of the statute’s enumerated predatory offenses and “convicted of” that offense or another offense “arising out of the same set of circumstances” must register as a predatory offender. Minnesota is or is close to unique in imposing predatory-offender registration on every person who has been charged with, but not convicted of, a statutorily enumerated predatory offense and who has been convicted of a non-predatory offense arising out of the same circumstances as the charged predatory offense.

Appellant Chad Loran Siegel was charged with two counts of kidnapping—a predatory offense under the predatory-offender-registration statute—as well as attempted second-degree murder and first-degree assault related to an incident where Siegel and accomplices beat victim J.A.L. The case went to trial. The trial court entered a judgment of acquittal on the kidnapping charges. The jury found Siegel not guilty of attempted second-degree murder but guilty of assault. Based on the kidnapping charge and the assault conviction—the latter of which is not an enumerated offense requiring registration under the predatory-offender-registration statute—the Minnesota Bureau of Criminal Apprehension (BCA) required Siegel to register as a predatory offender.

This case requires us to resolve whether a person who has been charged with an offense requiring registration as a predatory offender and acquitted of that offense by entry of a judgment of acquittal at trial, but convicted of another offense arising out of the same set of circumstances, must register under section 243.166, subdivision 1b(a)(1). We conclude that, under the Minnesota Constitution, requiring Siegel to register in such circumstances violates his right to substantive due process. Therefore, we reverse the decision of the court of appeals and remand to the court of appeals to address an issue it did not reach—whether Siegel’s claim is barred by the statute of limitations.

FACTS

The relevant facts in this case are not disputed. In April 2013, Siegel, several accomplices, and a witness met J.A.L. at a gas station in Superior, Wisconsin. Inside the vehicle, Siegel and his accomplices argued with J.A.L. and assaulted him. Siegel then drove to a street corner in Duluth where he and his accomplices removed J.A.L. from the car and beat him. Siegel and his accomplices initially left J.A.L. in the street, but they returned, put J.A.L. back into the car, and dropped him off at a residence in Superior. The occupants of the residence brought J.A.L. to the hospital, where doctors determined he had serious injuries.

On May 29, 2013, the State charged Siegel by amended complaint with one count of attempted second-degree murder, Minn. Stat. §§ 609.19, subd. 1(1), 609.17; one count of first-degree assault, Minn. Stat. § 609.221, subd. 1; and two counts of kidnapping,

Minn. Stat. § 609.25, subd. 1(2).1 Kidnapping is a predatory offense under the predatory- offender-registration statute. See Minn. Stat. § 243.166, subd. 1b(a)(1)(ii). Siegel did not challenge probable cause for any counts in the complaint.

The matter proceeded to a jury trial. At the close of the State’s case, Siegel moved for judgment of acquittal on the attempted-murder and kidnapping charges. The trial court denied Siegel’s motion as to the attempted-murder charge but concluded there was insufficient evidence for a reasonable jury to find Siegel guilty of kidnapping and entered judgments of acquittal on both kidnapping charges.

The jury found Siegel guilty of first-degree assault and not guilty of second-degree attempted murder. The trial court convicted Siegel of first-degree assault. The court later sentenced Siegel for that offense and notified him that he was required to register as a predatory offender under the predatory-offender-registration statute.2 Siegel appealed his conviction and sentence but did not challenge the requirement that he register as a predatory offender. State v. Siegel, No. A14-0669, 2015 WL 1608762 (Minn. App. Apr. 13, 2015), rev. denied (Minn. June 16, 2015). The court of appeals affirmed the trial court. Id. at *6.

1 The State originally charged Siegel with unintentional second-degree murder, in violation of Minnesota Statutes section 609.19, subdivision 2(1). It later filed an amended complaint that instead charged Siegel with intentional second-degree murder, in violation of Minnesota Statutes section 609.19, subdivision 1(1). 2 The trial court incorrectly notified Siegel that he was required to register for life, rather than for a period of 10 years. Compare Minn. Stat. § 243.166, subd. 6(a) (setting forth circumstances requiring a 10-year registration period), with id., subd. 6(d) (setting forth circumstances requiring a lifetime registration period).

In August 2022, Siegel sued respondent Drew Evans in his official capacity as the Superintendent of the BCA.3 Siegel argued that requiring him to register as a predatory offender based on the dismissed kidnapping charge was a violation of his procedural and substantive due process rights and that it violated the predatory-offender-registration statute. Siegel also argued that the predatory-offender-registration statute is an unconstitutional bill of attainder. Siegel brought suit under the United States and Minnesota Constitutions and 42 U.S.C. § 1983.

Siegel and the BCA filed cross-motions for summary judgment. The district court concluded that Siegel’s claims were barred by the statute of limitations and granted the BCA’s summary judgment motion. The district court also, however, stated that the trial court’s judgment of acquittal on Siegel’s kidnapping charges “necessarily acts as [a] collateral determination that the [kidnapping] charge was unsupported by probable cause.” Consequently, the district court stated that if the statute of limitations did not bar Siegel’s claim, it would conclude that Siegel’s acquittal on the kidnapping charge barred the BCA, as a matter of law, from requiring Siegel to register as a predatory offender.

Siegel appealed the district court’s decision. Siegel v. Evans, No. A24-0594, 2024 WL 4750882 (Minn. App. Nov. 12, 2024). The court of appeals affirmed the district court’s grant of summary judgment. Id. at *5. In reaching its decision, the court of appeals declined to address whether Siegel brought his claim after the statute of

3 Although Siegel brought his suit against Evans in his official capacity as Superintendent of the BCA, because the parties generally refer to respondent as the BCA, we follow suit and refer to respondent as the BCA.

limitations expired. Id. at *2. Instead, the court of appeals concluded that Siegel’s acquittal on the kidnapping charge did not bar imposition of the registration requirement. Id. at *4–5.

Free access — add to your briefcase to read the full text and ask questions with AI

Chad Loran Siegel v. Drew Evans, (Mich. 2026).

Chad Loran Siegel v. Drew Evans (Chad Loran Siegel v. Drew Evans) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Weinberger v. Salfi
422 U.S. 749 (Supreme Court, 1975)
Minnesota v. Clover Leaf Creamery Co.
449 U.S. 456 (Supreme Court, 1981)
State v. Bourke
718 N.W.2d 922 (Supreme Court of Minnesota, 2006)
Boutin v. LaFleur
591 N.W.2d 711 (Supreme Court of Minnesota, 1999)
Doe v. Poritz
662 A.2d 367 (Supreme Court of New Jersey, 1995)
State v. North Star Research & Development Institute
200 N.W.2d 410 (Supreme Court of Minnesota, 1972)
Contos v. Herbst
278 N.W.2d 732 (Supreme Court of Minnesota, 1979)
State v. Wakefield
278 N.W.2d 307 (Supreme Court of Minnesota, 1979)
Kaiser v. State
641 N.W.2d 900 (Supreme Court of Minnesota, 2002)
Nicollet Restoration, Inc. v. City of St. Paul
533 N.W.2d 845 (Supreme Court of Minnesota, 1995)
Thiele v. Stich
425 N.W.2d 580 (Supreme Court of Minnesota, 1988)
State v. Lopez
778 N.W.2d 700 (Supreme Court of Minnesota, 2010)
Miller Brewing Co. v. State
284 N.W.2d 353 (Supreme Court of Minnesota, 1979)
Schowalter v. State
822 N.W.2d 292 (Supreme Court of Minnesota, 2012)
Rew ex rel. T.C.B. v. Bergstrom
845 N.W.2d 764 (Supreme Court of Minnesota, 2014)
State v. Holloway
916 N.W.2d 338 (Supreme Court of Minnesota, 2018)