State v. CA (1981)

C.A., 304 N.W.2d at 358; P.A.D., 436 N.W.2d at 810 .

C.A., 304 N.W.2d at 358; P.A.D., 436 N.W.2d at 810 .

We said in C.A. that the judiciary has inherent authority to control court records. 304 N.W.2d at 361 (“The clerk is subject to the inherent power of the court to control its internal records.”).

Second, when a petitioner's constitutional rights are not involved, "the court must decide whether expungement will yield a benefit to the petitioner commensurate with the disadvantages to the public from the elimination of the record and the burden on the court in issuing, enforcing and monitoring an expungement order." C.A., 304 N.W.2d at 358.

Barlow, 365 N.W.2d at 233 ; State v. C.A., 304 N.W.2d 353, 357 (Minn.1981).

Barlow, 365 N.W.2d at 233 ; State v. C.A., 304 N.W.2d 353, 357 (Minn.1981).

Both parties agree, however, that the trial judge did not address a third basis for expungement: the "inherent power enabling courts to grant relief when it is necessary to the performance of their unique judicial functions." State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

Both parties agree, however, that the trial judge did not address a third basis for expungement: the “inherent power enabling courts to grant relief when it is necessary to the performance of their unique judicial functions.” State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

Alternatively, the court may use its inherent authority “to control court records . . . in order to reduce or eliminate unfairness to individuals, even though the unfairness is not of such intensity as to give a constitutional dimension.” State v. C.A., 304 N.W.2d 353, 358 (Minn. 1981).

The supreme court stated that “[t]he judiciary possesses inherent authority to expunge criminal records when expungement is ‘necessary to prevent serious infringement of constitutional rights.’ ” Id. (quoting State v. C.A., 304 N.W.2d 353, 358 (Minn.1981)).

The supreme court stated that "[t]he judiciary possesses inherent authority to expunge criminal records when expungement is `necessary to prevent serious infringement of constitutional rights.'" Id. (quoting State v. C.A., 304 N.W.2d 353, 358 (Minn.1981)).

In so doing, the supreme court wrote that "`courts must proceed cautiously' when invoking inherent authority," id. at 278 (quoting State v. C.A., 304 N.W.2d 353, 359 (Minn.1981)), particularly "because our separation of powers jurisprudence requires that we give `due consideration' to the `equally important executive and legislative functions,'" id. (quoting In re Clerk of Lyon County Courts' Comp., 308 Minn. 172, 182 , 241 N.W.2d 781, 786 (1976)).

In so doing, the supreme court wrote that “ ‘courts must proceed cautiously’ when invoking inherent authority,” id. at 278 (quoting State v. C.A., 304 N.W.2d 353, 359 (Minn.1981)), particularly “because our separation of powers jurisprudence requires that we give ‘due consideration’ to the ‘equally important executive and legislative functions,’ ” id. (quoting In re Clerk of Lyon County Courts’ Comp., 308 Minn. 172, 182 , 241 N.W.2d 781, 786 (1976)).

The judiciary possesses inherent authority to expunge criminal records when expungement is “necessary to prevent serious infringement of constitutional rights.” State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

The judiciary possesses inherent authority to expunge criminal records when expungement is "necessary to prevent serious infringement of constitutional rights." State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

Third, a court has inherent judicial authority to engage in activities that are necessary to the performance of judicial functions, but “the judiciary is not to resort to inherent authority when doing so would not ‘respect the equally unique authority of another branch of government.” State v. M.D.T., 831 N.W.2d 276, 280, 282 (Minn.2013) (quoting State v. C.A., 304 N.W.2d 353, 359 (Minn.1981)).

This authority only extends to a court’s “unique judicial functions.” State v. C.A., 304 N.W.2d 353, 358-59 (Minn.1981).

State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

State v. C.A., 304 N.W.2d 353, 358-61 (Minn. 1981).

State v. C.A., 304 N.W.2d 353, 358-61 (Minn.1981).

Because the court’s inherent authority extends only to its unique judicial functions, we “proceed cautiously in exercising that authority in order to respect the equally unique authority of the executive and legislative branches of government over their consti tutionally authorized functions.” State v. C.A., 304 N.W.2d 353, 358-59 (Minn.1981) (citations omitted).

As such, we shall not disturb the district court’s expungement of all judicial records relating to Schultz’s conviction. 2 See State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

Records and documents to be expunged or controlled should be described specifically by location, file number, book and page number, or similar description. 304 N.W.2d at 360 (emphasis in original).

Records and documents to be expunged or controlled should be described specifically by location, file number, book and page number, or similar description. 304 N.W.2d at 360 (emphasis in original).

State v. C.A., 304 N.W.2d 353, 358 (Minn. 1981) (“The inherent authority of the courts to control the performance of judicial functions is well established.”) (citations omitted).

If, and only if, the district court concludes that expungement is necessary to the performance of a judicial function, it must then determine “whether expungement will yield a benefit to the petitioner commensurate with the disadvantages to the public from the elimination of the record and the burden on the court in issuing, enforcing and monitoring an expungement order.” State v. C.A., 304 N.W.2d 353, 358 (Minn. 1981).

The district court has inherent authority to order expungement of criminal records held in the judicial branch as part of “the inherent power of the court to control its internal records.” M.D.T., 831 N.W.2d at 282 (quoting State v. C.A., 304 N.W.2d 353, 361 (Minn.1981)).

See Barker v. Wingo, 407 U.S. 514, 522 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972) (recognizing dismissal of charges as remedy for violation of defendant’s constitutional right to a speedy trial); State v. S.L.H., 755 N.W.2d 271, 274 (Minn.2008) (“The judiciary possesses inherent authority to expunge criminal records when ex-pungement is ‘necessary to prevent serious infringement of constitutional rights.’ ” (quoting State v. C.A., 304 N.W.2d 353, 358 (Minn.1981))).

A district court has inherent authority to expunge records when "necessary to the performance of [] unique judicial functions." State v. C.A., 304 N.W.2d 353, 358 (Minn. 1981).

A district court has inherent authority to expunge records when “necessary to the performance of [] unique judicial functions.” State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

Far from mandating the exercise of inherent judicial authority in other contexts, the supreme court has recognized the discretionary nature of this decision, see, e.g., State v. Hart, 723 N.W.2d 254, 259-60 (Minn.2006) (reviewing for abuse of discretion district court’s decision to use its statutory and inherent judicial authority to dismiss complaint in interests of justice), and has admonished district courts to proceed cautiously when exercising that authority so as to “r…

The Minnesota Supreme Court has recognized inherent expungement authority “affecting court records and agents of the court” but has directed that the courts “proceed cautiously in exercising that authority in order to respect the equally unique authority of the executive and legislative branches of government over their constitutionally authorized functions.” State v. C.A., 304 N.W.2d 353, 358-59 (Minn.1981).

State v. C.A., 304 N.W.2d 353, 358 (Minn.1981); In re Clerk of Court’s Compensation v. Lyon County Comm’rs, 308 Minn. 172, 177 , 241 N.W.2d 781, 784 (1976).

See, e.g., Doe v. Manson, 183 Conn. 183, 187 , 438 A.2d 859, 862 (1981); State v. C.A., 304 N.W.2d 353, 361-362 (Minn.1981). 4 However, since the statute permits retention of non-public records by the court for its own purposes, and since we already have in place a method of making records non-public in other types of cases, we shall adopt that method for cases arising under section 33-541(e)(2). 5 It is therefore ORDERED that: 1.

State v. C.A., 304 N.W.2d 353, 357-58 (Minn.1981); In re R.L.F., 256 N.W.2d 803, 808 (Minn.1977).

See State v. C.A., 304 N.W.2d 353, 358 (Minn.1981).

See State v. C.A., 304 N.W.2d 353, 358 (Minn.1981); State v. Osterloh, 275 N.W.2d 578, 580 (Minn.1978); Clerk of Court's Compensation for Lyon County v. Lyon County Comm'rs, 308 Minn. 172, 180 , 241 N.W.2d 781, 786 (1976); City of St.

Journey I, 850 P.2d at 666 ; see also State v. CA., 304 N.W.2d 353, 357-58 (Minn.1981) (holding that the judiciary's inherent authority includes both "the power to fashion relief necessary to prevent serious infringement of constitutional rights" and the power to "reduce or eliminate unfairness to individuals, even though the unfairness is not of such intensity as to give a constitutional dimension"). 7 .

See State v. C.A., 304 N.W.2d 353, 359 (Minn.1981) (noting that “courts must proceed cautiously in exercising [inherent] authority in order to respect the equally unique authority of the executive and *578 legislative branches of government over their constitutionally authorized functions.”).

See State v. C.A., 304 N.W.2d 353 , 357 n. 3 (Minn.1981) (holding that conviction remanded on appeal but not retried was resolved in defendant’s favor, warranting expunction); State v. L.K., 359 N.W.2d 305, 307-08 (Minn.App.1984) (holding that dismissal after yearlong continuance was determination warranting expunction).