Valerie R. LeMaster, et al. v. Federal National Mortgage Association

Minnesota eviction law specifically provides that "either party may demand a trial by jury" and that "the proceedings in the action are the same as in other civil actions." On the day of the scheduled eviction trial, petitioners' trial by jury was usurped by a late-filed dispositive motion, the court ruled from the bench on a dispositive motion, over petitioners' written and oral objections, without consideration of petitioners' written argument and supporting documents which had been lost by the clerk of court's office. The Minnesota Court of Appeals relied on the Mathews Eldridge procedural due process balancing test finding that additional procedural protections in eviction cases "would cause delay and likely considerable expense." The court went on to state, "We conclude that the district court did not violate appellants' procedural due process rights.., by ruling from the bench on appellants' summary judgment motion, even if such ruling occurred before the court reviewed their pleadings." The questions presented are then: Is the Mathews v. Eldridge (Mathews) balancing test, as it now stands, appropriate for use by a court when the court is weighing a civil litigant's constitutionally protected property rights against the court's perception of its own time and expense resources? AND If the Mathews balancing test is appropriate in civil litigation, what factors should be considered when a civil litigant's constitutionally protected property right is weighed against the court's own resources?