McCaughtry v. City of Red Wing
831 N.W.2d 518
Minn.2013Background
- Nine landlords and two tenants challenge Red Wing's rental inspection/licensing ordinance (RDLC) as unconstitutional under Minn. Const. art. I, §10.
- District court granted City summary judgment on standing and merits; City’s warrant procedures not fully argued on record.
- Court of Appeals affirmed on standing; McCaughtry v. City of Red Wing (McCaughtry I) reversed for ripeness; remanded for merits.
- On remand, court of appeals affirmed district court’s merits ruling; RDLC deemed not unconstitutional on its face.
- This Court reviews facial challenge de novo and holds that RDLC can be applied constitutionally with individualized suspicion in a given case, thus facial challenge fails.
- Court preserves as-applied questions for future consideration; no opinion on whether Minnesota Constitution forbids administrative warrants absent individualized suspicion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RDLC Licensing Inspections violate art. I, §10 on its face. | Appellants contend no individualized suspicion needed for Licensing Inspections. | City contends warrant can be conditioned by courts; not unconstitutional in all applications. | Facial challenge fails; can be applied constitutionally with suspicion in some cases. |
| Whether the RDLC can require individualized suspicion despite text allowing administrative warrants. | RDLC contemplates suspicionless Licensing Inspections. | Court may require suspicion in a given case; ordinance not unconstitutional in all applications. | A district court may require individualized suspicion; not unconstitutional in all applications. |
| Whether McCaughtry I governs dispositively on ripeness and facial challenge. | McCaughtry I supports ripe, purely legal facial challenge. | McCaughtry I addressed ripeness, not merits; not controlling on facial validity. | McCaughtry I does not dispositively control mer its; merits must be analyzed anew. |
| Whether Minnesota Constitution provides greater protection than Camara requires for admin warrants. | Minnesota law requires individualized suspicion; Camara standard insufficient. | Camara standard adaptable; Minnesota may defer to federal standard in some aspects. | Minnesota requires individualized suspicion in applicable cases; not dictated to follow Camara entirely. |
| What is the proper constitutional standard for reasonableness in Minnesota home inspections? | Home privacy demands heightened scrutiny; warrantless inspections are presumptively unreasonable. | Reasonableness balanced with public interest; administrative warrants permissible. | Reasonableness with individualized suspicion is required; potential as-applied challenges remain. |
Key Cases Cited
- Camara v. Municipal Court, 387 U.S. 523 (1967) (admin warrants require probable cause; not specific dwelling knowledge required)
- Wash. State Grange v. Wash. State Republican Party, 552 U.S. 442 (2008) (facial challenges disfavored; need set of constitutional applications)
- Minn. Voters Alliance v. City of Minneapolis, 766 N.W.2d 683 (Minn. 2009) (facial challenges require showing unconstitutional in all applications)
- McCaughtry v. City of Red Wing, 808 N.W.2d 331 (Minn. 2011) (ripeness/justiciability; facial challenge discussed)
- City of Lakewood v. Plain Dealer Pub. Co., 486 U.S. 750 (1988) (allow limiting construction in facial challenges; presume narrowing construction)