22 N.W.3d 181
Minn. Ct. App.2025Background
- Sela Investments (landlord) filed an eviction action against J.H. (tenant) in December 2023, alleging breach of lease; the parties settled, and J.H. vacated the property as agreed.
- J.H. subsequently moved for expungement of the eviction case record after fulfilling the settlement terms, citing Minn. Stat. § 484.014, subd. 3(a)(6).
- The district court granted the expungement automatically, solely under the statute, without considering opposing arguments or exercising discretion.
- Sela appealed, challenging the constitutionality of the statute on separation-of-powers grounds, arguing the statute usurped judicial discretion over court records.
- The case was complicated procedurally because the expungement was granted before the appeal period expired, but the appeal was still timely.
Issues
| Issue | Plaintiff's Argument (Sela) | Defendant's Argument (J.H.) | Held |
|---|---|---|---|
| Does Minn. Stat. § 484.014, subd. 3(a)(6) violate separation of powers? | The statute removes judicial discretion and authority to control records. | The statute only creates a remedy and does not limit judicial power. | Yes; it is facially unconstitutional for infringing on judicial authority. |
| Did the district court err by granting expungement solely under the statute? | Yes, because the expungement was automatic and not a judicial decision. | No, the statute requires expungement if conditions are met. | Yes; district court erred, order reversed and remanded. |
Key Cases Cited
- In re Greathouse, 248 N.W.2d 735 (Minn. 1933) (discussing courts’ inherent powers under the state constitution)
- Sharood v. Hatfield, 210 N.W.2d 275 (Minn. 1973) (striking down statute infringing judicial authority)
- State v. C.A., 304 N.W.2d 353 (Minn. 1981) (affirming courts’ inherent authority to control performance of judicial functions including court records)
- State v. L.W.J., 717 N.W.2d 451 (Minn. 2006) (describing weighing of interests required in expungement decisions)
- In re Clerk of Lyon Cnty. Court’s Comp., 241 N.W.2d 781 (Minn. 1976) (judiciary has authority to manage its own records)