In re Civil Commitment of Lonergan

Summary

The Minnesota Supreme Court held that patients indeterminately committed as sexually dangerous persons or persons with a sexual psychopathic personality may not use Minn. R. Civ. P. 60.02 to seek transfer or discharge, because the Minnesota Commitment and Treatment Act provides the exclusive procedures for that relief. However, the court rejected a blanket prohibition on Rule 60.02 motions and held that a narrow category of nontransfer, nondischarge claims may proceed if they do not conflict with the Act or frustrate rehabilitation or public safety. The court reversed in part and remanded the consolidated cases for further consideration of the claims raised by Lonergan and Kunshier.

Holdings

1. A patient indeterminately committed as a sexually dangerous person or person with a sexual psychopathic personality may not use Minn. R. Civ. P. 60.02 to seek a transfer or discharge because the Commitment Act provides the exclusive procedures for that relief.
2. A blanket prohibition on Rule 60.02 motions by patients indeterminately committed as sexually dangerous persons or persons with sexual psychopathic personalities is improper.
3. The cases must be remanded to the Minnesota Court of Appeals to determine what, if any, nontransfer and nondischarge claims the patients raised.

Questions Presented

1. Whether the Minnesota Commitment and Treatment Act conflicts with or is inconsistent with Minn. R. Civ. P. 60.02 such that an individual indeterminately committed as a sexually dangerous person or person with a sexual psychopathic personality may not invoke Rule 60.02.
2. Whether Rule 60.02 may be used to seek a transfer or discharge from an indeterminate civil commitment.
3. Whether Rule 60.02 remains available for narrow nontransfer, nondischarge claims that do not conflict with the Commitment Act or frustrate rehabilitation or public safety.

Disposition

reversed_and_remanded