State v. M.D.T.
2012 Minn. App. LEXIS 34
Minn. Ct. App.2012Background
- Respondent M.D.T. altered a prescription for a cold medicine containing codeine, leading to a felony charge for aggravated forgery and related offenses.
- Respondent entered an Alford plea to one aggravated forgery count; the district court stayed imposition of sentence, placed her on three years’ probation, and fined her, later discharged and fine forgiven.
- Respondent petitioned for expungement of judicial branch records twice; the first petition was denied, the second granted after substantial rehabilitative evidence.
- District court ordered expungement of judicial branch records and sealing of certain executive branch records, citing the court’s inherent authority and public/private interests.
- State challenged the breadth of authority to expunge executive branch records; the court conducted a five-factor HA analysis to assess benefits and burdens.
- This appeal addresses whether the district court abused its discretion expunging judicial records and whether it exceeded authority by sealing executive branch records.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion expunging judicial records | M.D.T. contends insufficient rehabilitation evidence; burden on court. | District court properly balanced interests under HA factors and inherent authority. | No abuse of discretion; expungement affirmed. |
| Whether the court exceeded authority to expunge executive branch records | Executive records should be sealed or expunged by court as needed to protect rights. | S.L.H. restricts executive-record expungement; separation-of-powers limits relief. | No error; sealing executive records upheld as part of remedy. |
Key Cases Cited
- State v. S.L.H., 755 N.W.2d 271 (Minn. 2008) (inherent authority; five-factor benefit/burden test for expungement)
- State v. Ambaye, 616 N.W.2d 256 (Minn. 2000) (inherent authority; abuse of discretion standard)
- State v. N.G.K., 770 N.W.2d 177 (Minn. App. 2009) (evidence sufficiency for expungement; executive records discussion)
- State v. M.L.A., 785 N.W.2d 768 (Minn. App. 2010) (expungement of executive branch records; S.L.H. guidance postulates)
- State v. V.A.J., 744 N.W.2d 674 (Minn. App. 2008) (expungement of records disseminated to executive agency)