https://en.wikipedia.org/wiki/Huygens_(spacecraft)
Distance is measured by the probe's exact distance from the center of Earth at the time of the landing. So for example another probe landing on Titan could cause this market to resolve YES if Titan was at a point in its orbit further from Earth at the time.
I don't think anything is going to land further out than Saturn before 2040. The Uranus Orbiter, if it happens, would arrive 2044. This should give some sense of the unlikelihood of an as yet unplanned mission making it earlier.
I can't find an exact date for Dragonfly's landing. Huygens landed when Saturn was in opposition, minimizing the distance to Earth. If Dragonfly does the same, playing around with this website https://www.fourmilab.ch/cgi-bin/Solar indicates that it will be a closer landing.
@Isaac228c Clarified that I'm measuring distance exactly, so Dragonfly could beat it depending on the point in Earth and Saturn's orbits when it lands.
@IsaacKing are you measuring it at the moment of landing, or at any time when the probe is active on the surface?