Michael Thomas Pruden v. One 2003 Jeep, VIN: 1J4GL58KX3W534613, MN License: KJK 096

CourtCourt of Appeals of Minnesota
DecidedMay 18, 2015
DocketA14-1313
StatusUnpublished

This text of Michael Thomas Pruden v. One 2003 Jeep, VIN: 1J4GL58KX3W534613, MN License: KJK 096 (Michael Thomas Pruden v. One 2003 Jeep, VIN: 1J4GL58KX3W534613, MN License: KJK 096) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Thomas Pruden v. One 2003 Jeep, VIN: 1J4GL58KX3W534613, MN License: KJK 096, (Mich. Ct. App. 2015).

Opinion

This opinion will be unpublished and may not be cited except as provided by Minn. Stat. § 480A.08, subd. 3 (2014).

STATE OF MINNESOTA IN COURT OF APPEALS A14-1313

Michael Thomas Pruden, et al., Appellants,

vs.

One 2003 Jeep, VIN: 1J4GL58KX3W534613, MN License: KJK 096, Respondent.

Filed May 18, 2015 Affirmed Ross, Judge

Hennepin County District Court File No. 27-CV-13-17252

Max A. Keller, Lexie D. Stein, Keller Law Offices, Minneapolis, Minnesota; and

Joel Heiligman, Minneapolis, Minnesota (for appellants)

Lori Swanson, Attorney General, St. Paul, Minnesota; and

Paul D. Baertschi, Stephen M. Tallen, Tallen and Baertschi, Minneapolis, Minnesota (for respondent)

Considered and decided by Kirk, Presiding Judge; Ross, Judge; and Reilly, Judge.

UNPUBLISHED OPINION

ROSS, Judge

Michael Pruden drove while intoxicated after having been convicted of the same

crime two years earlier. Pruden’s parents, who owned the car he was driving, fought to prevent the arresting agency from taking the car by forfeiture. They based their challenge

on the “innocent owner” defense available under Minnesota Statutes section 169A.63,

subdivision 7(d) (2014). The district court found that Pruden’s parents failed to

demonstrate that they lacked constructive knowledge that Pruden would drive while

intoxicated. We affirm because the evidence supports that finding.

FACTS

Michael Pruden spent an August 2013 late evening at a bar drinking before he

drove away in his parents’ 2003 Jeep Liberty. Pruden was quite intoxicated. Medina

Police stopped and arrested him and determined from a breath test that he had an alcohol

concentration of .26—more than three times the per se intoxication limit. The state

charged Pruden with gross misdemeanor impaired driving, and he pleaded guilty. The

City of Medina seized the Jeep.

Although Bradley Pruden and Beth Kielty-Pruden own the Jeep, they permitted

their son Michael Pruden to be its primary driver. They let Michael drive the Jeep despite

knowing that in October 2011 he was convicted of driving the Jeep drunk. And both

parents knew that Michael had driven home in the Jeep intoxicated more than once after

the 2011 conviction. They attempted to convince him only through conversation that

driving while impaired “was probably not the best approach for his life in general,” but

they put no restrictions on his use of the Jeep and they did not even monitor his use of it.

They did not know where Michael was or what he was doing the night of his August

2013 arrest.

2 After the city seized the Jeep and commenced a statutory forfeiture procedure, the

parents demanded its return based on the commonly called “innocent owner” affirmative

defense. The district court found that they failed to prove by clear and convincing

evidence that they lacked constructive knowledge that the Jeep would be used

unlawfully. It also found that they did not establish that they took reasonable steps to

prevent Michael from using the car. The district court ordered the Jeep forfeited to the

Medina Police Department. This appeal follows.

DECISION

I

The Prudens argue that the district court misinterpreted the affirmative defense to

forfeiture set out in Minnesota Statutes section 169A.63, subdivision 7(d). They contend

that they need not prove that they lacked constructive knowledge that Michael Pruden

would use their car unlawfully and that the burden of proof rests instead on the state.

Although they did not raise this burden-of-proof argument in the district court, we will

address it in the interest of justice. See Minn. R. Civ. App. P. 103.04.

The Prudens’ challenge raises an issue of statutory interpretation. We interpret

statutes de novo. Nielsen v. 2003 Honda Accord, 845 N.W.2d 754, 756 (Minn. 2013).

And we interpret a statute according to its plain language when the language is

unambiguous. Patino v. One 2007 Chevrolet, 821 N.W.2d 810, 813 (Minn. 2012). The

burden assignment in the forfeiture statute is unambiguous. A vehicle is “presumed

subject to forfeiture” if the state proves that it was used to commit certain offenses,

including Michael’s impaired-driving offense. See Minn. Stat. § 169A.63, subds. 7(a),

3 9(e) (2014). A statutory affirmative defense prevents forfeiture “if [the vehicle’s] owner

can demonstrate by clear and convincing evidence that the owner did not have actual or

constructive knowledge that the vehicle would be used or operated in any manner

contrary to law.” Id., subd. 7(d). Another provision explains, “A claimant bears the

burden of proving any affirmative defense raised.” Id., subd. 9(e). The statute is clear. It

explicitly places the burden of proof on the unaware owner who seeks to prevent

forfeiture.

We are not persuaded otherwise by the Prudens’ contention that requiring owners

to prove the affirmative defense renders the second sentence of the statutory defense

meaningless. That sentence states, “If the offender is a family or household member of

the owner and has three or more prior impaired driving convictions, the owner is

presumed to know of any vehicle use by the offender that is contrary to law.” Id., subd.

7(d). Because the burden-placement subdivision is unambiguous, we need not undertake

the exercise of construing the statute based on the Prudens’ theory that the plain-language

interpretation makes one of its provisions superfluous. Even so, the argument is

unavailing because one can read the two relevant sentences of 7(d) giving full effect to

both. Each sentence covers different ground than the other. That is, the first sentence

informs us that the “owner” is the party who must “demonstrate by clear and convincing

evidence” that he or she “did not have actual or constructive knowledge that the vehicle

would be used or operated in any manner contrary to law,” while the next informs us that,

in addition to being harnessed with the burden to prove that the offender would not use

the car illegally, in specific circumstances the owner will in fact be “presumed to know”

4 that the offender used the car unlawfully. The provisions are complementary and neither

renders the other meaningless.

II

The Prudens argue that, as a matter of fact, the record proves their lack of

constructive knowledge of their son’s unlawful use and that their innocent-owner defense

therefore prevails. We will reverse a district court’s fact findings only if they are clearly

erroneous. Rife v. One 1987 Chevrolet Cavalier, 485 N.W.2d 318, 321 (Minn. App.

1992), review denied (Minn. June 30, 1992). The findings are not clearly erroneous. The

district court found that the parents knew that Michael was previously convicted of

impaired driving, that they took no measure to restrict or even monitor his driving, that

Kielty-Pruden knew that Michael had driven home while intoxicated after his 2011

conviction more than once, and that she had informed her husband of Michael’s repeat

infractions. These findings have ample support in the evidentiary record, and we will

therefore rely on them.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Thiele v. Stich
425 N.W.2d 580 (Supreme Court of Minnesota, 1988)
Schoepke v. Alexander Smith & Sons Carpet Co.
187 N.W.2d 133 (Supreme Court of Minnesota, 1971)
Woodruff v. 2008 Mercedes
831 N.W.2d 9 (Court of Appeals of Minnesota, 2013)
Nielsen v. 2003 Honda Accord
845 N.W.2d 754 (Supreme Court of Minnesota, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Michael Thomas Pruden v. One 2003 Jeep, VIN: 1J4GL58KX3W534613, MN License: KJK 096, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-thomas-pruden-v-one-2003-jeep-vin-1j4gl58kx3w534613-mn-license-minnctapp-2015.