State v. M.D.T.
2013 Minn. LEXIS 275
| Minn. | 2013Background
- M.D.T. was convicted by Alford plea to aggravated forgery in 2007 and sentenced with probation; probation was completed and her felony was reduced to a misdemeanor upon early discharge in 2008.
- Approximately seven months after discharge, M.D.T. sought expungement of criminal records; the district court initially denied.
- M.D.T. filed a second expungement petition in 2011 supported by rehabilitation evidence and a narrative of hardship and career impact.
- The district court granted expungement, sealing all records across both judicial- and executive-branch entities, citing unclear precedent and relying on inherent judicial authority.
- The State appealed; the court of appeals affirmed, holding the district court could expunge records generated by the judiciary as well as sealing executive-branch records.
- The Minnesota Supreme Court reversed in part, holding the district court lacked authority to expunge executive-branch records, and the MDPA and public-data policies constrained such relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court has inherent authority to expunge executive-branch records | M.D.T. argues inherent authority allows sealing of executive records for full relief | State contends authority is limited; executive data must remain public | District court lacked inherent authority to expunge executive-branch records |
| Whether inherent authority to expunge extends to records held in the judicial branch but maintained by the executive | M.D.T. asserts authority to seal records disseminated to other agencies | State/majority limit to preserve separation of powers and public data policy | Inherent authority does not extend to records held in the executive branch from the judiciary (Type 1/2 records) per majority reasoning |
| Role of MDPA and public-data policies in expungement scope | Legislative data-public policy should permit broader expungement | MDPA presumes public data; 15-year rule restricts expungement | Legislative policy controls; expungement of executive records not allowed under MDPA considerations |
| Impact of separating powers on district courts' expungement remedies | Separation of powers allows meaningful relief through inherent authority | Judicial authority must defer to legislative and executive domains | Separation of powers supports limited inherent authority; no authority to reach executive records for expungement |
Key Cases Cited
- State v. S.L.H., 755 N.W.2d 271 (Minn. 2008) (discusses scope of inherent authority to expunge; threshold questions)
- State v. C.A., 304 N.W.2d 353 (Minn. 1981) (recognizes expungement can involve control of court records; balancing test later applied)
- Ambaye, 616 N.W.2d 256 (Minn. 2000) (inherent authority question not addressed as threshold in that case)
- In re Quinn, 517 N.W.2d 895 (Minn. 1994) (discusses limits of inherent authority and separation of powers)
- Barlow v. Comm’r of Pub. Safety, 365 N.W.2d 232 (Minn. 1985) (recognizes judicial control over records but cautions separation of powers)