Styczinski v. Arnold

Synopsis

Styczinski v. Arnold, 46 F.4th 907 (C.A.8 (Minn.), 2022)

Background

Coin dealers and association of coin dealers brought § 1983 action against Commissioner of Minnesota Department of Commerce, seeking both declaratory and injunctive relief, and contending that statute regulating bullion product dealers violated the dormant Commerce Clause. The United States District Court for the District of Minnesota, 550 F.Supp.3d 637, partially granted and partially denied plaintiffs’ motion for summary judgment and partially granted and partially denied Commissioner’s motion to dismiss for failure to state a claim.

Plaintiffs appealed.

Holdings

The Court of Appeals held that: registration provisions in Minnesota statute regulating bullion transactions violated the dormant Commerce Clause under the doctrine of extraterritoriality; and surety bond requirement violated the dormant Commerce Clause under the doctrine of extraterritoriality.

Reversed and remanded.