## Facts

- Bloomington police investigated an alleged rape involving Peter Daniel Quinn after an encounter in a Bloomington hotel room on November 10, 1992.
- The police chief concluded a sexual assault occurred and recommended prosecution, but the city attorney declined to file criminal charges.
- Quinn obtained a temporary restraining order limiting disclosure of investigative information and then sought expungement and sealing of the law-enforcement records, asserting harm to his professional reputation.
- Jane Doe (the complainant) and two friends sought access to the records and redaction of their names.
- Media entities intervened seeking access to the investigative file under the Minnesota Government Data Practices Act (MGDPA).
- The district court denied access to all requesters and ordered the investigative records expunged and sealed; the court of appeals affirmed.

## Issues

1. Whether a district court may order expungement and sealing of inactive police investigative data in a manner that denies access otherwise required by the MGDPA.
2. Whether a suspect’s reputational or asserted property interests authorize judicial relief that conflicts with the MGDPA’s statutory classification and disclosure rules for inactive investigative data.

## Decision

- The Minnesota Supreme Court reversed the court of appeals and held the district court erred in ordering expungement and sealing of the law-enforcement records.
- The court concluded the records were “inactive” law-enforcement investigative data because the investigation was complete and no charges were filed.
- The MGDPA’s access and classification scheme governed the data, and the district court’s expungement/sealing order violated the Act.
- Quinn’s asserted professional reputational interest did not justify overriding the legislature’s disclosure policy choices embodied in the MGDPA.

## Legal Principles

- When government data are expressly regulated by the MGDPA, courts lack authority to create remedies (including expungement or sealing) that conflict with the Act’s mandatory classification and access rules.
- “Inactive” law-enforcement investigative data are subject to the MGDPA’s statutory treatment; a court may not nullify that scheme by ordering records erased or sealed absent statutory authorization.
- Reputational interests, without more, do not permit judicial action that converts statutorily accessible investigative data into nonpublic or unavailable records.

## Conclusion

The Minnesota Supreme Court held that a district court cannot expunge or seal inactive police investigative records in a way that contravenes the MGDPA’s statutory framework, and that a suspect’s claimed reputational harm does not supply authority to override the Act’s disclosure rules.


In re Quinn, 517 N.W.2d 895 (Minn. 1994)