The Legal Argument for Dismissal

The foundation of any criminal case is probable cause—the requirement that charges be supported by facts, not assumptions. In this case, the state claims that Willis engaged in a “concealment scheme” to secretly control the business. But the evidence shows the opposite:

• Willis was openly listed in official filings with the Secretary of State as early as 2013.
   
• Government agencies corresponded with other managers, not Willis, acknowledging a transparent management structure.
   
• Consulting agreements and power-of-attorney documents confirm that Willis’s role was legitimate, authorized, and out in the open.
   

A “concealment scheme” cannot exist when the facts show disclosure. Without probable cause, the prosecution has no legal ground to proceed.

At its core, the state’s case confuses administrative compliance with criminal conduct. Even if there were disagreements about paperwork, management changes, or regulatory filings, these are administrative matters, not crimes.

Legal precedent—most notably the Mohamud case—makes this clear: the state cannot elevate administrative issues into criminal charges. By ignoring this distinction, prosecutors are attempting to criminalize normal business operations and fiduciary responsibilities, setting a dangerous precedent for all businesses in Minnesota.

Under Minnesota law, the state must overcome any “rational hypothesis of innocence.” In this case, the defense has presented compelling evidence that points directly to innocence:

• The Power of Attorney demonstrates that Willis acted legally on his mother’s behalf.
   
• Medical records confirm why fiduciary authority was necessary—his mother’s cognitive impairment required it.
   
• The Koelfgen payroll fraud investigation and related documents point to alternative explanations for alleged irregularities, none of which implicate Willis in fraud.
   

Together, these facts form a consistent and rational explanation of innocence that the state cannot disprove.