In the Matter of the Civil Commitment of Edward Everett Urbanek

Summary

The Minnesota Court of Appeals affirmed the denial of Edward Everett Urbanek’s motions for relief under Minnesota Rule of Civil Procedure 60.02 from his indeterminate civil commitment. The court held that Minnesota Statute Chapter 253D does not provide a constitutional right to self-representation in initial civil-commitment proceedings and that the structural-error doctrine does not apply to an alleged violation of a statutory right to self-representation. The court also held that In re Civil Commitment of Benson did not establish a constitutional right to self-representation or warrant relief in Urbanek’s case.

Holdings

1. Benson did not establish or address a constitutional right to self-representation in initial civil-commitment proceedings. Benson was a statutory decision concerning whether an already committed person could seek to waive counsel in commitment-appeal-panel proceedings under Minnesota Statutes section 253D.20.
2. Neither the Fourteenth Amendment nor the Sixth Amendment provides a constitutional right to self-representation in the initial civil-commitment proceedings at issue.
3. Even assuming a statutory right to self-representation existed and was violated, the structural-error doctrine does not apply to a district court's failure to honor a party's attempted waiver of the statutory right to counsel in a civil-commitment proceeding.
4. The district court did not abuse its discretion in denying Urbanek's Rule 60.02(e) and (f) motions because he failed to demonstrate a qualifying change in decisional law or any entitlement to relief.

Questions Presented

1. Whether In re Civil Commitment of Benson recognized a constitutional right to self-representation in initial civil-commitment proceedings.
2. Whether the Sixth or Fourteenth Amendment provides a constitutional right to self-representation in civil-commitment proceedings.
3. Whether an alleged denial of a statutory right to waive counsel and represent oneself in a civil-commitment proceeding is structural error requiring automatic reversal.
4. Whether the district court abused its discretion by denying Urbanek's Rule 60.02(e) and (f) motions.

Disposition

affirmed