JUDICIAL AUTHORITY
Universal injunctions

Trump v. Casa, 145 S.Ct. 2540 (2025)

The facts: Numerous individuals, organizations, and states filed three separate suits to block the implementation and enforcement of three separate executive orders issued by President Donald Trump.

The type of case: In each case, the district court issued a “universal injunction,” which bars government officials from enforcing a particular law, regulation, or policy against anyone in the entire country, not just the specific parties involved in the lawsuit. The universal injunctions were upheld by the Court of Appeals.

The issues: The U.S. Supreme Court reviewed whether the federal courts have equitable authority to issue universal injunctions under the Judiciary Act of 1789.

The court’s ruling: The Supreme Court decided that federal courts cannot issue universal injunctions, which block a law or policy for everyone. When Congress passed the Judiciary Act of 1789, it gave federal courts the same powers that equity courts had at the time. Equity courts — unlike regular courts that awarded money damages — handled cases where money wasn’t enough and could order remedies like injunctions. But those traditional powers did not include universal injunctions. This means federal courts can only issue injunctions that apply to the people actually involved in a lawsuit.

What this means for cities: To be covered by a court’s ruling or injunction, cities may need to join the lawsuit directly — either by being named as plaintiffs or by becoming part of a certified class action.

EMINENT DOMAIN
Attorney fees

State of Minnesota vs. Williams, A24-1713 (Minn. Ct. App. Aug. 4, 2025)

The facts: As part of a highway improvement, the Minnesota Department of Transportation (MnDOT) petitioned to condemn a temporary construction easement and a permanent highway easement over Mike’s Holiday property, which included a convenience store, a canopy, and two rows of gas-pump islands with 16 fueling stations.

The type of case: Mike’s Holiday’s objection to the eminent domain petition was denied by the district court. MnDOT requested the district court appoint commissioners to appraise the damages. The commissioners filed a report with the district court, awarding $210,017 to Mike’s Holiday as just compensation for the easements. Both parties appealed the ruling. A settlement agreement followed, reserving Mike’s Holiday’s right to seek reasonable attorney fees and expenses. The district court concluded that Mike’s Holiday was entitled to attorney fees and expenses pursuant to Minnesota Statutes, section. 117.031.

The issues: MnDOT appealed, arguing the district court improperly awarded attorney’s fees not authorized by statute because they included expenses related to the failed objection to condemnation. MnDOT also claimed the court abused its discretion in calculating the award.

The court’s ruling: The court ruled that Minnesota Statutes, section 117.031(a) does not limit attorney fees to work securing a damages award. Fees may also include work done defending against a condemnation petition.

What this means for cities: When making offers related to eminent domain proceedings, cities should be aware that they may be liable for property owners’ attorney fees throughout the entire eminent domain process.

CRIMINAL LAW
Search and seizure

In the Matter of the Welfare of: C.T.B., A23-0459 (Minn. Aug. 13, 2025)

The facts: Minneapolis police officers responded to a report of a man in a yellow and black coat (the “original suspect”) pointing a handgun at people near a light rail station. Officers located the original suspect at a nearby restaurant. Through the restaurant window, an officer saw a black male wearing a yellow jacket with black sleeves. The officer also saw other people near the original suspect including 16-year-old C.T.B. Fearing the original suspect’s handgun may be passed to others due to the earlier incident, one of the officers pat-frisked C.T.B. and found a handgun in the front pocket of his sweater.

The type of case: C.T.B. was charged with unlawfully possessing a firearm while under 18 years old. He moved to suppress the handgun evidence found during the frisk, claiming the officers lacked a reasonable suspicion that C.T.B. was armed and dangerous when they conducted the search. The district court denied C.T.B.’s motion, finding the search reasonable because weapons can be passed off to bystanders and C.T.B. was near the original suspect.

The issues: The Minnesota Supreme Court considered whether physical proximity to a suspect involved in an alleged crime is enough to support reasonable, articulable suspicion (explainable suspicion based on observable facts) to conduct a warrantless search.

The court’s ruling: Citing the U.S. Supreme Court ruling in Terry v. Ohio, the court reiterated that police may frisk someone without probable cause if there is a reasonable suspicion the person is armed and dangerous. The reasonableness of an officer’s suspicion is judged by an objective examination of the totality of the circumstances. Here, the court determined that there were no facts to support a conclusion that C.T.B. had a connection with the original suspect other than being nearby. Without facts showing some other connection between the parties, the court determined that the pat-frisk of C.T.B. was improper.

What this means for cities: When officers conduct a pat-frisk of someone they think may be connected to a suspect, they must have a clear, specific reason for suspicion beyond just that person’s location near the suspect.

Written by Kyle Hartnett, assistant research manager with the League of Minnesota Cities. Contact: [email protected] or (651) 215-4084.