State of Minnesota v. A. K. N., A16-776

Background

In July 2013 A.K.N. struck her 13-year-old son (and struck her husband when he intervened); she pleaded guilty to gross-misdemeanor malicious punishment of a child; domestic-assault charge was dismissed.
The district court stayed adjudication, placed A.K.N. on supervised probation for one year, and later discharged her from probation and dismissed the malicious-punishment charge.
DHS conducted a background study and disqualified A.K.N. from serving as a personal-care attendant; MDH reviews DHS background-study disqualifications on reconsideration.
A.K.N. petitioned to expunge her criminal records under Minn. Stat. § 609A.02 after becoming statutorily eligible; DHS and MDH objected, citing public-safety concerns for vulnerable populations.
The district court granted expungement generally but excluded DHS and MDH from the expungement order, finding their access to the records necessary to protect vulnerable individuals; A.K.N. appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred by denying DHS/MDH access to expunged records	A.K.N.: court relied on dismissed-charge facts, failed to make sufficiently individualized findings, effectively exempted DHS/MDH from statute	DHS/MDH: specific facts show a particularized public-safety risk if they lose access to the records relevant to disqualification decisions	Court: affirmed—DHS/MDH presented particularized harm; court made case-specific findings and narrowly limited the denial
Whether statutory one-year eligibility requires automatic expungement	A.K.N.: eligibility after one year suffices for expungement	DHS/MDH: one-year eligibility does not eliminate the court’s duty to weigh statutory factors when an agency objects	Court: one-year petition right does not mandate expungement when objection raises statutory factors; court properly considered time since offense
Whether the district court’s findings were sufficiently individualized	A.K.N.: findings were generic and inadequate under R.H.B. precedent	DHS/MDH: findings addressed nature of offense, risk to vulnerable populations, and recency—sufficiently particularized	Court: findings were individualized and tied to statutory factors; distinguished R.H.B.
Whether the denial improperly exempted DHS/MDH from expungement law	A.K.N.: exclusion amounted to exemption from statute	DHS/MDH: exclusion was narrowly tailored to prevent particularized harm while leaving other records sealed	Court: not an exemption; denial was narrowly tailored and based on particular facts; no abuse of discretion

Key Cases Cited

State v. M.D.T., 831 N.W.2d 276 (Minn. 2013) (standard of review for expungement decisions is abuse of discretion)
State v. R.H.B., 821 N.W.2d 817 (Minn. 2012) (agency opposing expungement must show unique or particularized harm beyond generalized assertions)
State v. Rick, 835 N.W.2d 478 (Minn. 2013) (statutory interpretation: follow plain meaning when text is unambiguous)