Southern Glazer's Wine and Spirits, LLC v. Harrington

Background

Southern Glazer’s Wine and Spirits, LLC and Southern Glazer’s Wine and Spirits of Minnesota, LLC sued John Harrington, in his capacity as Commissioner of the Minnesota Department of Public Safety, seeking a declaration that the Coleman Act—an earlier version of Minnesota Statute section 340A.307—was unconstitutional and an injunction against its future enforcement. Harrington agreed that the Coleman Act violated the dormant Commerce Clause, a constitutional rule limiting state laws that discriminate against or improperly burden interstate commerce.

On March 29, 2022, the court granted Southern’s motion for judgment on the pleadings and held that the earlier version of the Coleman Act was unconstitutional. The court stayed entry of judgment for 60 days while proposed legislation was pending in the Minnesota Legislature. The court later clarified that the judgment remained stayed.

While the stay was in effect, the Minnesota Legislature amended the Coleman Act, effective May 23. The parties agreed that the amendment made the case moot and that the judgment should be prevented and vacated. Intervenors Johnson Brothers Liquor Company and Bellboy Corporation asked the court to go further by vacating the March 29 order itself.

Court’s analysis

The court explained that appellate courts commonly vacate decisions when events outside the parties’ control make a case moot on appeal. Vacatur removes a decision’s binding effect and prevents an unreviewable decision from producing legal consequences. But the court concluded that Intervenors had not shown that a district court must follow the same practice when a case becomes moot before judgment has been entered.

The court distinguished the cited appellate precedent because, in that matter, judgment had been entered and was stayed during an appeal. Here, the court stated that judgment had never been entered and that the March 29 order had no legal consequences or binding effect. The court also noted that vacatur is an equitable remedy, not an automatic right, and that Intervenors had not shown that vacating the order would serve the public interest. The court found that its explanation of the case’s procedural history adequately addressed any possible confusion.

Ruling

The court denied Intervenors’ Motion for Vacatur. It denied Intervenors’ Motion for Relief from Clerical Mistake as moot, denied Intervenors’ Motion to Stay as moot, and vacated the Judgment in the case. The March 29 order itself remained in place. The order was signed by Chief Judge John R. Tunheim.