Halva v. Minnesota State Colleges and Universities, A19-0481 (Minn. App., Dec. 16, 2019).

The appellant in this case brought a district court action against respondents including a claim for damages pursuant to the Data Practices Act, and an action to compel compliance with the Data Practices Act and the Minnesota Official Records Act. The District Court dismissed the Data Practices Act claims due to the fact that the plaintiff previously brought an action to compel compliance at the Office of Administrative Hearings (OAH) and also dismissed two other claims unrelated to the Data Practices Act and Official Records Act. The only surviving claims related to the Official Records Act. Respondents subsequently argued that the Official Records Act does not provide a private right of action and moved for a judgment on the pleadings, which the district court granted.

The appellant appealed the District Court’s dismissal of the Data Practices Act claim for damages and the granted motion for judgment on the pleadings related to the Official Records Act.

The Minnesota Court of Appeals held that the appellant did not adequately plead damages, and thus the dismissal was upheld. Further, the court determined that the judgment on the pleadings was also proper, as the Official Records Act does not create a private cause of action.

In its opinion, the Court noted that although appellant brought an action to compel compliance with the Data Practices Act at OAH, this did not prohibit him from seeking damages in district court. However, because appellant did not sufficiently plead damages, the district court’s dismissal was appropriate.

State v. Cruz, No. A19-0344 (Minn. Ct. App., Dec. 30, 2019) (unpublished).

The Minnesota Court of Appeals affirmed a district court’s decision to deny a motion to suppress evidence gathered under a search warrant law enforcement obtained with an application including private data.

A sheriff’s deputy arrested appellant Cruz for driving with a canceled license. As part of the county jail’s booking process, appellant was asked to provide a urine sample, which tested positive for methamphetamine. A jail sergeant provided the test results to the deputy, who submitted a search warrant application to a district court to obtain a blood sample for testing. The application included the urine sample test results. The court granted the warrant, and the blood sample tested positive for methamphetamine. Appellant was charged with a gross misdemeanor driving after cancellation and a misdemeanor driving while under the influence of a controlled substance.

Appellant moved to suppress the blood test results, arguing the search warrant was invalid because it was based on improper sharing of private medical data between jail staff and the deputy. However, the district court determined urine sample test results were private “corrections and detention data” under the Data Practices Act (Minn. Stat. § 13.85, subd. 2) and held private corrections and detention data may be released to “any law enforcement agency, if necessary for law enforcement purposes” according to § 13.85, subd. 5. The court denied the motion to suppress and found appellant guilty on both counts.

On appeal, appellant challenged the denial of his motion to suppress evidence by expanding his argument to suggest Minn. Stat. 13.85, subd. 5 did not authorize disclosure of private data to the district court because it was within the judiciary rather than a law enforcement agency. The appellant argued that disclosure of the private urine sample test results in the search warrant application violated the Data Practices Act, making the search warrant invalid, and the blood test results should be suppressed.

The Minnesota Court of Appeals disagreed, noting Minn. Stat. §13.85 must be read in its entirety. The Court stated the disclosure of the urine sample test results to the district court did not violate the Data Practices Act because search warrants serve a law enforcement purpose. Additionally, the Court found that the language of § 13.85, subd. 4 considers classification of private and confidential corrections and detention data after it is shared with courts, indicating such data can be disclosed to courts for law enforcement purposes. Finally, the Court determined that appellant’s argument would lead to absurd results if adopted because law enforcement could be prevented from providing confidential or protected nonpublic criminal investigative data (Minn. Stat. § 13.82, subd. 7) to courts, which would hamper obtaining search warrants and criminal investigations.