McCaughtry v. City of Red Wing
2011 Minn. LEXIS 768
| Minn. | 2011Background
- City of Red Wing rental inspection ordinance requires inspections for operating licenses, by consent or administrative warrants.
- Appellants (nine landlords, two tenants) refused consent and challenged prior warrant applications; district court dismissed declaratory claims for lack of standing.
- Court of Appeals affirmed dismissal; Supreme Court reverses to consider justiciability of the constitutional challenge.
- The City amended the ordinance twice; third warrant application sought in 2009 against appellants, who again challenged constitutionality.
- Declaratory judgment action sought a facial constitutional ruling under Minnesota Constitution regarding administrative warrants and housing inspections.
- Court frames issue as whether the controversy is justiciable (ripeness/standing) and whether the challenges are appropriate for declaratory relief before warrant issuance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there a justiciable controversy to challenge the RDLC's administrative-warrant scheme? | Appellants have ongoing, concrete interests and ongoing enforcement actions create imminent injury. | No imminent injury; standing requires present injury or ripe controversy only after warrant issue. | Yes, justiciable; remanded to address merits. |
| Whether Minnesota Constitution provides greater protection than the U.S. Constitution against administrative warrants for housing inspections. | Minnesota Constitution prohibits searches without individualized probable cause; greater protection than Fourth Amendment. | Federal standards apply; Minnesota lacks clearer articulation; not ripe for constitutional determination at this stage. | The issue is ripe for merits review on remand; no decision on merits here. |
Key Cases Cited
- Onvoy, Inc. v. ALLETE, Inc., 736 N.W.2d 611 (Minn. 2007) (articulates justiciability standards for declaratory judgments)
- Jasper v. Comm’r of Pub. Safety, 642 N.W.2d 435 (Minn. 2002) (limits of issuing advisory opinions; avoidance of pointless rulings)
- Holiday Acres No. 3 v. Midwest Fed. Savs. & Loan Ass’n of Minneapolis, 271 N.W.2d 445 (Minn. 1978) (Declaratory Judgments Act remedial and liberally construed)
- Barron v. City of Minneapolis, 212 Minn. 566 (Minn. 1942) (standing to test municipal ordinances in declaratory actions)
- Koppinger v. City of Fairmont, 311 Minn. 186 (Minn. 1976) (facial validity of ordinances in declaratory actions)
- Constr. & Gen. Laborers Union Local 563, AFL-CIO v. City of St. Paul, 270 Minn. 427 (Minn. 1965) (limits on municipal regulatory schemes)
- Seiz v. Citizens Pure Ice Co., 207 Minn. 277 (Minn. 1940) (limits on declaratory relief to actual controversy)
- Kennedy v. Carlson, 544 N.W.2d 1 (Minn. 1996) (requirement of actual injury for justiciability)
- State ex rel. Smith v. Haveland, 223 Minn. 89 (Minn. 1946) (injury in fact and ripeness principles for declaratory actions)
- Minneapolis Fed’n of Men Teachers, Local 238, AFL v. Bd. of Educ. of Minneapolis, 238 Minn. 154 (Minn. 1952) (ripeness and preventative purposes of declaratory actions)
- Blanchette v. Conn. Gen. Ins. Corp., 419 U.S. 102 (U.S. Supreme Court) (court may consider constitutionality even if future enforcement possible)
- National Park Hospitality Ass’n v. Dep’t of the Interior, 538 U.S. 803 (U.S. Supreme Court) (ripeness doctrine and pre-enforcement challenges)
- Duke Power Co. v. Carolina Envtl. Study Grp., Inc., 438 U.S. 59 (U.S. Supreme Court) (ripeness and legal issues precede factual development)
- Gray v. City of Valley Park, 567 F.3d 976 (8th Cir. 2009) (pre-enforcement facial challenge to regulation permitted when direct and immediate impact alleged)