## Facts

- Karl and Dianne Auleciems owned a large single-family home in the Town of West Lakeland, Minnesota—about 14,000 square feet, with seven bedrooms and nine bathrooms.
- Starting in 2017, the Auleciemses advertised the property for short-term rentals on sites such as VRBO and rented it for large gatherings, including weddings and family reunions.
- Neighbors complained about noise, traffic, and related disruptions.
- At the time, a township ordinance prohibited short-term rentals, and the Town sued to stop the rental activity.
- The district court issued interim injunctive relief (including a temporary restraining order and a temporary injunction) and later entered a permanent injunction (in May 2019) barring short-term renting of the property without a township permit.
- After the permanent injunction, the Town continued to receive reports that the property was being rented on multiple weekends.
- The district court ordered the Auleciemses to show cause why they should not be held in contempt for violating the injunctions.
- At the contempt hearing, the Town presented evidence of post-injunction rental activity. Karl testified that he removed online listings but admitted he “shared” the home with guests for compensation while he or another resident remained on-site.
- In October 2019, the district court found the Auleciemses in civil contempt and imposed three sanctions: (1) an $81,870 fine; (2) payment of the Town’s attorney fees and costs; and (3) a 180-day jail term, to be lifted only upon full payment of the fines (including a previously imposed fine for violating the preliminary injunction) and fees.
- The Auleciemses appealed the October 2019 contempt order.

## Issues

1. Whether the district court’s October 2019 “civil contempt” sanctions were criminal in substance—requiring criminal-contempt procedures—because they operated primarily as punishment rather than coercion or compensation.
2. Whether the incarceration and monetary sanctions were valid civil-contempt remedies, including whether the contemnors had a meaningful purge condition tied to compliance within their present ability.

## Decision

- The Minnesota Court of Appeals reversed the October 2019 contempt order and remanded for further proceedings.
- The court held that the district court erred by imposing sanctions that were criminal in nature based on a finding of civil contempt.
- The court stated that its ruling did not affect earlier orders; prior injunction-related orders, including the district court’s June 2019 order, remained binding on the parties.

## Legal Principles

- Civil contempt is remedial: sanctions must be designed to coerce compliance with a court order or to compensate the injured party, not to punish past violations.
- Criminal contempt is punitive: sanctions such as fixed jail terms or fines imposed for completed misconduct are criminal in nature and require the procedural protections applicable to criminal contempt.
- Courts classify contempt by the substance and effect of the sanction, not by how the district court labels the proceeding.
- A valid civil-contempt sanction typically provides a realistic purge condition—an affirmative act the contemnor can perform, within present ability, to avoid or end the sanction.
- Conditioning incarceration on payment of substantial sums may be improper in a civil-contempt setting when the structure and effect resemble punishment rather than coercion tied to compliance.

## Conclusion

Because the October 2019 fine and 180-day jail sanction functioned as criminal punishment despite being imposed in a civil-contempt proceeding, the Court of Appeals reversed and remanded, while leaving the earlier injunction orders in place and enforceable.


Town of West Lakeland v. Auleciems, 2021 WL 79789 (2021)