The question of whether a district court has subject matter jurisdiction is a legal question subject to de novo review on appeal. In Minnesota, statutory forfeiture can occur by either judicial or administrative action. In forfeiture by judicial action, the jurisdiction of the court is invoked by the state's filing of a complaint against the property subject to forfeiture. Id. , subd. The claimant waives the right to challenge the forfeiture if no demand for judicial determination is made.
Civil forfeitures involving court action are in rem proceedings.
Penn Gen. Cas. Appellant claims that her filing of a complaint seeking a judicial determination of the administrative forfeiture action conferred jurisdiction on the district court. Generally, under Minnesota law, the service of a complaint in a civil action confers jurisdiction upon the district court. See Minn. R. Civ. Here, appellant's filing of a complaint seeking a judicial determination was the first action by any of the parties invoking the jurisdiction of any court, either state or federal.