The Minnesota Supreme Court affirmed the constitutionality of penalties imposed for unemployment benefit fraud in *Christopher Thigpen v. Best Home Care LLC*, ruling that Minnesota's statutory framework does not violate constitutional protections against excessive fines.
The case centers on Christopher Thigpen, who received unemployment benefits from the Department of Employment and Economic Development (DEED) for 104 weeks from March 2020 to March 2022. An unemployment law judge later determined that Thigpen had been overpaid $24,005 in standard unemployment benefits and pandemic emergency unemployment compensation, along with $15,600 in federal pandemic unemployment benefits.
The unemployment law judge concluded these overpayments resulted from Thigpen's misrepresentation of his employment status. Under Minnesota Statute Section 268.18, subdivision 2(a), Thigpen became required to repay the overpayment along with a penalty of 40 percent of the overpayment amount.
Thigpen challenged the penalty as a violation of the Excessive Fines Clauses of both the United States Constitution's Eighth Amendment and Article I, Section 5 of the Minnesota Constitution. The constitutional challenge questioned whether the 40 percent penalty was proportionate to the underlying misconduct.
The Minnesota Supreme Court, in an opinion authored by Justice Moore III, rejected Thigpen's constitutional challenge. The court held that the penalty under Minnesota law for obtaining unemployment benefit overpayments through misrepresentation does not violate the Excessive Fines Clauses of either constitution.
The decision comes at a time when unemployment fraud penalties have faced increased scrutiny nationwide, particularly following the expanded unemployment programs implemented during the COVID-19 pandemic. The case involved both standard unemployment benefits and federal pandemic-related compensation programs that were administered by state agencies.
The court's analysis focused on the constitutional standards for determining whether a penalty constitutes an excessive fine. Courts typically examine factors including the gravity of the offense, the harshness of the penalty, and the penalties imposed in similar statutes when evaluating excessive fines challenges.
Thigpen was represented by Russell Squire and Brianna Boone from Southern Minnesota Regional Legal Services, Inc. The Department of Employment and Economic Development was represented by Keri A. Phillips and Katrina Gulstad. Mid-Minnesota Legal Aid participated as amicus curiae, represented by Lars Markeson.
The case reached the Minnesota Supreme Court as case number A23-1544, with the decision filed on December 24, 2025. The opinion notes that Justices Hennesy and Procaccini dissented from the majority decision, though the content of their dissent was not detailed in the available materials.
The ruling provides important clarity for Minnesota's unemployment system regarding the enforcement of fraud penalties. State unemployment agencies have broad authority to recoup overpayments and impose penalties when they determine benefits were obtained through misrepresentation or other fraudulent means.
The 40 percent penalty rate established under Minnesota Statute Section 268.18 represents a significant financial consequence for individuals found to have fraudulently obtained benefits. Combined with the requirement to repay the full overpayment amount, recipients can face substantial financial obligations.
This decision reinforces the state's ability to deter unemployment fraud through meaningful financial penalties while operating within constitutional bounds. The ruling may influence similar challenges to unemployment fraud penalties in other jurisdictions that have comparable statutory frameworks.
The case also highlights the ongoing legal issues surrounding unemployment benefit administration, particularly as states continue to address fraud and overpayments that occurred during the expanded pandemic-era programs. Many states implemented emergency unemployment benefits with expedited processes that later led to increased overpayment determinations.
For unemployment recipients, the decision emphasizes the importance of accurate reporting when claiming benefits. Misrepresentation of employment status or other material facts can result in both the requirement to repay benefits and substantial additional penalties.
The Minnesota Supreme Court's affirmation of the penalty structure provides legal certainty for the Department of Employment and Economic Development in continuing its fraud enforcement efforts. The decision validates the state's approach to balancing deterrence against constitutional protections in unemployment benefit administration.
The ruling stands as Minnesota law on the constitutionality of unemployment fraud penalties under current statutory provisions, establishing precedent for future challenges to similar enforcement actions by state unemployment agencies.