Coker v. Jesson
2013 Minn. LEXIS 257
Minn.2013Background
- Coker was indeterminately committed in 2000 as a sexually dangerous person after offenses involving 15–17-year-old girls.
- He petitioned for provisional discharge from civil commitment; first-phase hearing held before the Appeal Panel.
- The Appeal Panel dismissed under Minn. R. Civ. P. 41.02(b); the court of appeals affirmed.
- The Supreme Court reversed and remanded, holding Rule 41.02(b) cannot be applied to provisional discharge petitions and the first-phase record must be viewed in Coker’s favor.
- Evidence included Coker’s progress at MSOP CPS, Dr. Alsdurf’s testimony, and various exhibits the Commissioner admitted.
- The Court clarified burden of production vs. persuasion and noted the State bears the burden of proof in the second phase.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 41.02(b) can be used to dismiss a provisional-discharge petition. | Coker argues Rule 41.02(b) cannot weigh the evidence or dismiss at the close of the first phase. | Commissioner contends Rule 41.02(b) allows dismissal after evidence if no right to relief is shown. | Rule 41.02(b) cannot be applied; evidence must be viewed in Coker’s light. |
| Whether the first-phase record satisfies the burden of production. | Coker met the burden by presenting competent evidence including Dr. Alsdurf’s testimony and favorable evidence. | Commissioner argues Dr. Alsdurf’s opinion that Coker is not ready forecloses production. | Coker met the burden of production when evidence is viewed in the light most favorable to him. |
| Whether, on remand, second-phase proof follows with the State bearing burden. | Remand should allow proper application of statutory burdens in the second phase. | State bears clear and convincing burden in second phase to justify continued confinement. | Proceedings remanded for proper application of standards; no ruling on merits of discharge at this stage. |
Key Cases Cited
- Braylock v. Jesson, 819 N.W.2d 585 (Minn. 2012) (burden of production defined; prima facie evidence concept clarified)
- In re Civil Commitment of Lonergan, 811 N.W.2d 635 (Minn. 2012) (confirms rule in civil commitment proceedings about procedures)
- Call v. Gomez, 535 N.W.2d 312 (Minn. 1995) (statutory discharge criteria and burden framework cited)
- Paradise v. City of Minneapolis, 297 N.W.2d 152 (Minn. 1980) (viewing evidence in light favorable to the plaintiff in Rule 41.02(b) context)
- State ex rel. Burnquist v. Bollenbach, 241 Minn. 103 (1954) (court-trial provision allows weighing of credibility; not required to view in plaintiff’s favor for court-trial ruling)
- In re Blodgett, 510 N.W.2d 910 (Minn. 1994) (distinguishes burden of proof vs. burden of production in commitment context)
- State v. Bourke, 718 N.W.2d 922 (Minn. 2006) (constitutional argument not reached due to underlying ruling; rule avoidance principle)