Weidner Apartment Homes v. B. F.

Summary

The Minnesota Court of Appeals held that Minnesota Statutes section 484.014, subdivision 3(a)(5), is facially unconstitutional because its automatic, no-motion eviction-expungement requirement violates separation of powers and infringes on the judiciary’s authority to decide cases and manage its records. The court concluded that Weidner Apartment Homes had standing because the expungement resulted in the vacation of its money judgment. The court reversed the district court’s expungement and related orders and reinstated the money judgment.

Holdings

1. Weidner had standing because the district court's vacatur of the money judgment caused a concrete, particularized injury to Weidner's legally protected property interest.
2. Minnesota Statutes section 484.014, subdivision 3(a)(5), is facially unconstitutional because it violates the separation-of-powers doctrine by impairing the district court's ability to hear and decide cases and infringing on the judiciary's inherent authority to manage its own records.

Questions Presented

1. Whether Weidner had standing to challenge the constitutionality of Minnesota Statutes section 484.014, subdivision 3(a)(5).
2. Whether Minnesota Statutes section 484.014, subdivision 3(a)(5), is facially unconstitutional because it violates separation of powers by infringing on the judiciary's authority to hear and decide cases and to manage its own records.

Disposition

reversed