Sheriff’s Policy Says Complaints Should Be Logged and Audited. What Do the Records Show?
A public-data request is seeking the records behind the Carlton County Sheriff’s Office personnel-complaint system — including complaint logs, historical policies, annual audits and referrals for outside or criminal investigation.
by Carlton County Watch
When someone complains about the conduct of a Carlton County Sheriff’s Office employee, what happens next?
Is the complaint documented?
Does it receive a complaint number?
Is it entered into a central tracking system?
Who investigates it?
What happens if the alleged conduct may also constitute a crime?
And does anyone periodically examine that system to determine whether complaints are being recorded and handled as contemplated by Sheriff’s Office policy?
Those questions are now the subject of a continuing public-records inquiry involving the Carlton County Sheriff’s Office.
Carlton County Watch has reviewed copies of a Minnesota Government Data Practices Act requests seeking records concerning the Sheriff’s Office personnel-complaint system, together with correspondence concerning those requests.
Sheriff Kelly Lake has announced that she will retire when her current term concludes in January 2027 after approximately two decades as Carlton County Sheriff. Dan Danielson and Chad Walsh advanced from the August primary to the November 3 general election for sheriff.
This article does not advocate for or against either candidate.
Instead, it examines an institutional question that will remain after the election and after Sheriff Lake leaves office:
How does the Carlton County Sheriff’s Office document, track and review complaints concerning its own personnel?
The Sheriff’s own records should help answer that question.
The Current Policy Describes a Complaint-Tracking System
The Carlton County Sheriff’s Office publicly posts a Personnel Complaints Policy on the County website.
The current policy describes procedures for receiving, documenting and investigating complaints concerning Sheriff’s Office personnel.
Supervisors are directed to ensure formal and informal complaints are documented on complaint forms.
But the policy goes further.
It states:
“All complaints and inquiries should also be documented in a log that records and tracks complaints.”
The policy says that log shall include the nature of the complaint and the actions taken to address it.
That describes something more systematic than individual complaint files maintained by separate supervisors.
It describes a central accountability record:
A complaint log.
And that creates a straightforward question.
What does the complaint log show?
Minnesota Law Makes Important Complaint Information Public
Personnel investigations can contain information that legitimately is not public.
Carlton County Watch is not suggesting that every allegation, interview, investigative note or personnel record should be disclosed.
Minnesota law draws distinctions between public and not-public personnel data.
But Minn. Stat. § 13.43 makes one category particularly important for this investigation: the existence and status of complaints or charges against public employees are public regardless of whether the complaint ultimately resulted in disciplinary action.
When disciplinary action reaches a final disposition, additional information — including the final disposition, the specific reasons for the discipline and data documenting its basis — is also generally public, subject to statutory exceptions.
Thus, the public need not rely solely upon assurances that an internal accountability system exists.
Minnesota law gives the public access to important parts of that system.
The First Request Was Submitted July 29
Carlton County Watch has reviewed a copy of an MGDPA request submitted to Sheriff Kelly Lake on July 29, 2026.
That request seeks public information concerning complaints, employee-misconduct investigations, disciplinary actions and final dispositions involving current and former Carlton County Sheriff’s Office employees from January 1, 2020 forward.
Importantly, the request does not merely seek final disciplinary letters.
It specifically requests existing public information contained within any:
index;
register;
spreadsheet;
database;
log;
case-management system;
internal-affairs system;
professional-standards system;
personnel-tracking system; or
other compilation used to identify or track employee complaints and disciplinary matters.
It also seeks the public existence and status of complaints, final disciplinary dispositions, supporting public data, grievance and arbitration information, employment-related settlements and records concerning the destruction or disposition of responsive records.
In other words, the July 29 request already asks for the basic records from which the public should be able to see how employee complaints have moved through the Sheriff's accountability system since 2020.
September 8 Came and Went
According to correspondence reviewed by Carlton County Watch, Sheriff Lake advised on September 4 that records responsive to the July 29 request were anticipated to be available by September 8.
September 8 passed without notification that inspection could begin.
On September 9, the requester sent another communication asking whether the requested data were ready for inspection.
As of publication of this article, no response to that follow-up has been received.
That chronology should not be interpreted as establishing what the records ultimately will show.
It does not establish that complaint records are missing.
It does not establish that annual audits were or were not performed.
And it does not establish that the Sheriff’s complaint system failed.
It means simply that, at the time Phase I of this investigation is being published, the records requested July 29 have not yet been made available for inspection.
When those records become available, they can be examined on their merits.
Then Another Provision Emerged: The Complaint Log Is Supposed to Be Audited
While the July 29 request remained pending, a closer examination of the Sheriff’s current Personnel Complaints Policy revealed another potentially important element of the system.
The policy states that on an annual basis the Office/Systems Administrator “should ensure an audit of the log is completed” and send an audit report to the Sheriff or an authorized designee.
The precise wording matters.
The provision uses “should ensure” rather than “shall.”
Carlton County Watch therefore will not characterize that provision more strongly than the Sheriff’s own policy does.
But the policy plainly contemplates two things:
An annual audit of the complaint log.
An audit report provided to the Sheriff or designee.
That raises another series of factual questions.
Were those audits conducted?
For which years do audit reports exist?
Who performed them?
What did they examine?
Did any audit identify missing complaints, numbering discrepancies, recordkeeping deficiencies or other problems?
Were corrective measures recommended?
Were recommendations implemented?
And do the audit reports reconcile with the complaint records themselves?
Those records are now being requested.
A Supplemental Request Seeks the Audit Trail
Carlton County Watch has also reviewed an additional MGDPA request submitted to Sheriff Lake after the current Personnel Complaints Policy was examined.
The request seeks categories of records not clearly encompassed by the original request.
Among them are:
every version of the personnel-complaint policy dating to 2017;
records identifying when each version became effective;
historical complaint forms and procedural instructions;
complaint and inquiry tracking records for 2017 through 2019;
records concerning matters categorized as “inquiries” rather than complaints;
annual complaint-log audits;
annual audit reports;
audit findings and corrective-action records;
records identifying who was responsible for the complaint-log audit;
existing records concerning complaint numbering and follow-up;
outside-agency administrative-investigation referrals; and
existing public records concerning allegations referred for separate criminal investigation.
The distinction between the two requests is important.
The July 29 request asks principally what complaints and disciplinary matters exist.
The new data request asks something different:
What records show how the complaint-accountability system itself operated?
The Soderstrom Matter Shows Why the Records Matter
One issue remained unresolved after examining those disciplinary records:
Was the underlying conduct separately investigated or reviewed as potential criminal conduct?
A MGDPA request sought records specifically designed to answer that question.
The request sought, among other things:
any referral to a prosecuting authority;
records requesting criminal charging review;
outside law-enforcement referrals;
communications discussing potential criminal offenses;
records documenting a decision not to investigate or refer the matter;
any separate criminal case or incident number;
records identifying officials participating in a criminal-review decision; and
the policies governing suspected criminal conduct by Sheriff’s Office employees at the time.
Sheriff Lake responded on September 4.
According to the response reviewed by Carlton County Watch, the Sheriff’s Office reported that its search for records documenting whether the July 26, 2018 Soderstrom conduct was investigated or reviewed as potential criminal conduct produced no responsive data.
That response should be understood carefully.
It does not mean no records concerning Soderstrom exist.
Administrative and disciplinary records concerning the matter have already formed part of previous reporting.
Nor does the response establish what policy governed the matter in 2018.
The response is narrower:
That leaves another important question.
What Does the Complaint System Say About Soderstrom?
Once the historical policies and complaint-tracking records are available, the Soderstrom matter provides one concrete example against which the system can be examined.
Questions include:
Was matter No. 18030365 entered into a personnel-complaint log or comparable tracking system?
If so, how was it categorized?
Was it considered a complaint, an inquiry, an internally generated matter or another type of case?
What action does the tracking system say was taken?
What disposition was recorded?
Was a complaint number assigned?
Did an annual audit encompass the record?
What did the Sheriff’s policy actually say in 2018 about handling employee allegations that potentially involved criminal conduct?
What records show whether the applicable 2018 procedures were followed?
None of those questions should be answered by assumption.
The historical policy and contemporaneous records should provide the evidence.
“Complaints” and “Inquiries” May Not Be the Same Thing
Another detail in the current policy deserves attention.
The policy recognizes circumstances that may constitute an “inquiry” rather than a formal personnel complaint.
Yet its recordkeeping provision refers to both categories.
It says “all complaints and inquiries” should be documented in the tracking log.
That seemingly small distinction could become significant.
Suppose information concerning employee conduct was received but never classified as a formal complaint.
Was it nevertheless placed in the tracking system as an inquiry?
If so, what happened next?
The data request specifically seeks existing public tracking information concerning such inquiries.
What If the Allegation May Be Criminal?
The current Personnel Complaints Policy also specifically addresses allegations of potential criminal conduct.
The policy states that when an Office member is accused of potential criminal conduct, a separate supervisor or investigator is to investigate the criminal allegations apart from the administrative investigation.
The current policy also provides that the Sheriff may request that an outside law-enforcement agency conduct the criminal investigation.
That provision creates another useful records question:
How often has that process been used?
The data request seeks existing public logs, indexes, referral records and other tracking information concerning allegations against Sheriff's Office personnel that were referred for separate criminal investigation, assigned to another investigator, referred to an outside law-enforcement agency or transmitted to a prosecuting authority.
Some underlying criminal-investigative material may legitimately be classified as not public under Minnesota law.
The request recognizes that limitation.
The purpose is not to demand protected investigative information.
The question is whether public records document when the separate-investigation mechanism was invoked.
What Happens When the Complaint Concerns the Sheriff?
The current policy also contemplates situations in which an outside investigation may be appropriate and provides special handling where the Sheriff herself is the subject of the complaint.
That makes sense as a structural matter.
An internal accountability system needs some mechanism for handling complaints involving the official who ordinarily sits at the top of that system.
The request therefore seeks existing public records documenting referrals of employee complaints for outside administrative investigation, including records concerning complaints in which the Sheriff was the subject.
At present, this publication does not know how many such records exist.
The production should help answer that question.
Complaint Numbers, Follow-Up and a Paper Trail
The current policy describes other steps that can create a measurable administrative trail.
For example, follow-up contact with a complainant “should be made within 24 hours” after the Office receives a complaint.
The policy further contemplates informing the complainant of the assigned investigator and complaint number after assignment.
These provisions suggest that the current system can generate identifiable milestones:
Complaint received.
Follow-up made.
Complaint assigned.
Complaint number issued.
Investigation conducted.
Disposition entered.
The request seeks existing records used to track those milestones.
Whether earlier versions of the policy contained identical benchmarks remains to be determined from the historical policies.
Why This Matters During a Change in Sheriffs
The timing adds another dimension to the inquiry.
Sheriff Kelly Lake announced in April that she will retire at the conclusion of her current term in January 2027 after serving approximately two decades as sheriff.
Carlton County voters will elect her successor in November. Dan Danielson and Chad Walsh advanced from the August primary to the November 3 general election.
The pending election does not determine what the records say.
Nor does this investigation advocate for either candidate.
But the approaching transition makes understanding the institutional practices of the Carlton County Sheriff’s Office particularly timely.
Complaint logs and audit reports are not merely records about one sheriff.
They concern a system that exists — or changes — across administrations.
The next sheriff will inherit responsibility for how complaints are received, how allegations against employees are documented, when outside investigation is appropriate, how potential criminal misconduct is handled and how the public can evaluate accountability within the Office.
Understanding the existing system therefore provides useful information about the institution that the next elected sheriff will lead.
The apple doesn’t fall far from the tree.
Let the Records Answer the Questions
A written policy tells the public how an agency describes its procedures.
Records provide evidence of how those procedures operated.
If the requested data show that complaints and inquiries were consistently documented, complaint numbers were assigned, appropriate referrals occurred and annual audits regularly examined the system, that is important information for the public.
If audits identified problems and those problems were corrected, that is important information too.
If records reveal gaps, inconsistent procedures or missing elements, those facts deserve examination on their own merits.
At this stage, none of those outcomes should be presumed.
The purpose of requesting the records is to find out.
What Phase II Should Be Able to Answer
When the requested data become available, and if shared, Carlton County Watch intends to examine questions including:
What complaint-tracking records actually exist?
What public complaint and status information do they contain?
How many matters were categorized as complaints and how many as inquiries?
What policies governed the system during different years?
Were annual complaint-log audits conducted?
What do the audit reports say?
Were deficiencies identified?
Were outside administrative investigations used?
Were allegations of potential criminal conduct separately investigated or referred?
How does the Soderstrom matter appear in the tracking system, if at all?
And do the records correspond with the policies actually in effect at the time?
Those are questions for the records — not speculation.
The Records Will Decide Phase II
Carlton County identifies Sheriff Kelly Lake as the responsible authority for Sheriff’s Office data requests.
Minnesota law provides public access to government data unless the data are otherwise classified by law. It also generally prohibits government entities from requiring a person seeking public government data to identify themselves or justify why the information is being requested, absent specific statutory authority.
The data requests discussed in this article seek existing public records — not answers created specifically for the requester.
The current Sheriff’s policy describes a complaint log.
It says complaints and inquiries should be entered into that log.
It says the log shall record the nature of the complaint and action taken.
And it says an annual audit of the log should be completed and an audit report provided to the Sheriff or designee.
The July 29 data request seeks the underlying complaint and disciplinary tracking information.
The supplemental request seeks the historical policies, audits, inquiry records and outside/criminal-investigation referral information that may reveal how the broader accountability system operates.
And the Sheriff's prior response concerning the Soderstrom matter provides a concrete reason to examine those systems more closely.
There is no need to guess what the records will show.
Review the policies.
Open the records.
Follow the entries.
Report the results.
That will be Phase II.
Editor’s note: The public-data requests discussed in this article were submitted to Carlton County Watch by the presumed data requestor. Before publication of this article Carlton County Watch has reviewed copies of the requests and related correspondence.