Thomas Styczinski v. Grace Arnold, No. 21-2936 (8th Cir. 2022)
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Appellants (the “Bullion Traders”) are a collection of in-state and out-of-state precious metal traders or representatives thereof challenging the constitutionality of Minnesota Statutes Chapter 80G, which regulates bullion transactions. The Bullion Traders argue the statute violates the dormant Commerce Clause.
The Eighth Circuit reversed the district court’s partial grant of the Commissioner’s motion to dismiss and the district court’s partial denial of the Bullion Traders’ motion for summary judgment. On remand, the court left to the district court to decide in the first instance whether the extraterritorial provisions of Chapter 80G, as amended, are severable from the remainder of the statute.
The court explained that certain in-state obligations, such as a registration fee for traders doing business in Minnesota, even when calculated considering out-of-state transactions, do not control out-of-state commerce. However, Chapter 80G does not merely burden in-state dealers with a monetary obligation that considers both in-state and out-of-state transactions. Rather, it prohibits an in-state dealer who meets the $25,000 threshold from conducting any bullion transaction, including out-of-state transactions, without first registering with the Commissioner.
Court Description: [Grasz, Author with Shepherd and Kobes, Circuit Judges] Civil case - Civil rights. In-state and out-of-state precious metal traders challenge the constitutionality of Minnesota Statute Chapters 80G, which regulate bullion transactions, on the ground the Chapter violates the dormant Commerce Clause. Held, Chapter 80G, even as amended, is unconstitutional; the recent amendments did not materially affect the conduct about which the traders complain and did not deprive the court of jurisdiction over the appeal; the registry and surety bond provisions of Chapter 80G violate the dormant Commerce Clause by imposing an excessive burden on interstate commerce and by having the practical effect of extraterritorial control; the district court's order partially granting the defendant's motion to dismiss and partially denying the traders' motion for summary judgment is reversed; on remand the court leaves it to the district court to determine in the first instance whether the extraterritorial provisions of Chapter 80G, as amended, are severable.
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