State of Minnesota, Ramsey County, City of St. Paul v. R. M. W., A16-906

Background

Appellant R.M.W., a disabled veteran living in St. Paul public housing, was charged in 2014 with first‑degree criminal sexual conduct; he admitted intercourse but asserted consent; a jury acquitted him in September 2014.
The St. Paul Public Housing Agency initiated an unlawful‑detainer action tied to the charge; R.M.W. later settled and agreed to vacate while PHA agreed to give a neutral housing reference.
After losing subsidized housing and alleging difficulty finding affordable housing, R.M.W. petitioned in October 2015 to expunge records related to the criminal charge; several public agencies opposed.
The district court recognized the statutory presumption in favor of sealing where proceedings were resolved in the petitioner’s favor but, after considering the factors in Minn. Stat. § 609A.03, subd. 5(c), denied expungement by finding respondents met the burden by clear and convincing evidence.
On appeal R.M.W. argued (1) the district court should not have applied the 12 statutory factors in § 609A.03(5)(c) to a case resolved in his favor and (2) the court improperly applied those factors in a manner that assumed guilt despite his acquittal.
The Court of Appeals affirmed that the 12 factors are mandatory to consider under subdivision 5(c), but reversed and remanded because the district court applied those factors inconsistently with the jury’s not‑guilty verdict (i.e., treated acquitted conduct as criminal).

Issues

Issue	Appellant's Argument	Respondents' Argument	Held
Whether the 12 factors in Minn. Stat. § 609A.03, subd. 5(c) apply when petitioner was acquitted and proceeds under § 609A.02, subd. 3(a)(1)	§ 609A.03(5)(c) should not apply to petitions under § 609A.02(3)(a)(1); § 609A.03(5)(b) governs and is the exclusive standard	The court should consider relevant evidence; factors help determine if public interest outweighs sealing even after acquittal	The statute’s plain language makes subdivision 5(c) mandatory for determinations under subdivision 5, so the 12 factors must be considered (affirmed)
Whether the district court abused its discretion by weighing factor (6) (reasons for expungement/housing hardship) against petitioner	The housing loss was a direct consequence of the charge; factor (6) should weigh for sealing	Respondents contended settlement and current housing undercut hardship claims	Appellate court found the district court’s credibility determinations and factual weighing were supported by the record; no abuse of discretion on factor (6)
Whether the district court improperly applied factors that reference the "crime" or "underlying crime" by treating allegations as proven despite an acquittal	The court impermissibly assumed culpability and re‑litigated guilt; findings treating conduct as criminal contradict the jury verdict	Respondents argued acquittal does not preclude considering the conduct under the lower civil/clear‑and‑convincing standard	Court held the district court abused its discretion where it made findings inconsistent with the jury’s not‑guilty verdict and characterized appellant’s conduct as criminal; remanded for reconsideration consistent with verdict
Appropriate remedy when factors are applied inconsistent with acquittal	Vacate and remand for reanalysis of the 12 factors in light of the acquittal	Respondents sought to uphold denial based on public safety concerns derived from victim’s statement	Court reversed in part and remanded for reconsideration applying the factors without assuming guilt

Key Cases Cited

State v. M.D.T., 831 N.W.2d 276 (Minn. 2013) (standard of review for expungement decisions)
State v. R.H.B., 821 N.W.2d 817 (Minn. 2012) (two‑step expungement procedure and rebuttable presumption)
State v. Ambaye, 616 N.W.2d 256 (Minn. 2000) (acquittal is a resolution in petitioner’s favor)
DeMars v. State, 352 N.W.2d 13 (Minn. 1984) (trial court credibility determinations and fact‑weighing)
Vangsness v. Vangsness, 607 N.W.2d 468 (Minn. App. 2000) (appellate court will not reweigh evidence)
Wilson v. Moline, 47 N.W.2d 865 (Minn. 1951) (appellate review of trial court findings)
Elliott v. Mitchell, 249 N.W.2d 172 (Minn. 1976) (affirming findings even if evidence could support different result)
Zander v. Zander, 720 N.W.2d 360 (Minn. App. 2006) (courts may not substitute appellate judgment for trial court’s)
Great River Energy v. Swedzinski, 860 N.W.2d 362 (Minn. 2015) (courts may not supply omitted statutory language)
State v. Hulst, 510 N.W.2d 262 (Minn. App. 1994) (statutory interpretation principles)
In re Winship, 397 U.S. 358 (1970) (reasonable‑doubt standard undergirds presumption of innocence)