In re Civil Commitment of Lonergan
2012 Minn. LEXIS 112
Minn.2012Background
- Lonergan and Kunshier were indeterminately civilly committed as SDP/SPP under Minnesota's Commitment Act.
- Both filed pro se Rule 60.02 motions seeking relief from their commitments; Lonergan sought discharge or treatment reform, Kunshier sought relief including discharge and issues with classification and ineffective assistance.
- The Minnesota Court of Appeals previously held Rule 60.02 cannot be used to seek discharge or challenge MSOP treatment as it conflicts with the Commitment Act.
- The supreme court held Rule 60.02 cannot be used to seek a transfer or discharge due to explicit Act procedures, but allowed a narrow category of nontransfer, nondischarge Rule 60.02 claims.
- The court remanded Lonergan and Kunshier to determine whether nontransfer, nondischarge Rule 60.02 claims (e.g., jurisdiction, ineffective assistance) may proceed.
- The decision reversed in part and remanded for further proceedings to assess the specific, nontransfer Rule 60.02 claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SDP/SPP Rule 60.02 relief conflicts with the Commitment Act. | Lonergan/Kunshier argues Rule 60.02 should apply for discharge or constitutional challenges. | State contends Act procedures control and preclude Rule 60.02 for discharge/constitutional challenges. | Rule 60.02 cannot be used for discharge/constitutional challenges where Act governs. |
| Whether Rule 60.02 may be used to seek nontransfer, nondischarge relief. | Rule 60.02 should fill gaps for nontransfer issues like jurisdiction or counsel ineffectiveness. | Act channels relief through Special Review Board and Panel; Rule 60.02 should be limited. | A narrow class of nontransfer, nondischarge Rule 60.02 claims may proceed. |
| What is the proper scope of relief under the Commitment Act vs Rule 60.02. | Rule 60.02 provides broader relief from judgment. | Act is exclusive for transfer/discharge; Rule 60.02 otherwise applicable only to narrow claims. | Commitment Act is exclusive for transfer/discharge; Rule 60.02 can apply to limited nontransfer claims. |
Key Cases Cited
- Thunderbird Motel Corp. v. Cnty. of Hennepin, 289 Minn. 289 (Minn. 1971) (inconsistency tests under 81.01(a))
- Guillaume & Assoc. v. Don-John Co., 336 N.W.2d 262 (Minn. 1983) (distinct conflicts control Rule 81.01(a))
- Tischendorf v. Tischendorf, 321 N.W.2d 405 (Minn. 1982) (distinct conflicts may render Rule 81.01(a) inapplicable)
- In re Brainerd Nat’l Bank, 383 N.W.2d 284 (Minn. 1986) (frustration of statute purpose may cause inconsistency)
- Ryan Contracting, Inc. v. JAG Invs., Inc., 634 N.W.2d 176 (Minn. 2001) (gap-filling role of a rule may govern when statute silent)
- K.B.C. v. Cnty. of Itasca, 308 N.W.2d 495 (Minn. 1981) (exclusive remedy framework for certain reforms)
- In re Civil Commitment of Lonergan, 792 N.W.2d 473 (Minn.App. 2011) (Rule 60.02 not mechanism for discharge from SDP commitment)