In the Matter of the Civil Commitment of: Jamie Allen Andrews., A16-237

Jamie Allen Andrews was civilly committed as a sexually dangerous person (SDP) in Jan. 2016 following juvenile and adult sexual-offense adjudications and an Alford plea to second-degree criminal sexual conduct and second-degree manslaughter stemming from injuries to his young child.
Andrews has a juvenile adjudication (1995) for sexual conduct with young boys, completed adolescent sex-offender treatment, and later reoffended against his own children (2006–07 allegations); he denied culpability for the later offenses and the manslaughter.
Experts (Drs. Gilbertson and Seifert) agreed Andrews met SDP criteria (course of harmful sexual conduct; sexual/personality disorder; high likelihood of reoffense) but disagreed on whether MSOP commitment was required—Dr. Gilbertson favored commitment; Dr. Seifert thought intensive supervised release (ISR) with community treatment might be possible.
Andrews proposed a post-release plan (halfway house short-term; uncertain long-term housing/employment) but lacked acceptance into community sex-offender programs; probation and experts testified community programs would not accept civilly committed persons and Alpha Human Services would not accept a civilly committed client.
The district court found Andrews met the statutory SDP criteria by clear and convincing evidence, found his denial and lack of treatment readiness made community-based options unlikely, and concluded no less-restrictive alternative to MSOP commitment was proved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for SDP commitment	Andrews: evidence insufficient; contested dates/credibility	County: convictions, victim reports, expert testimony support SDP findings	Court: affirmed—clear and convincing evidence supports commitment
Availability of a less-restrictive alternative (ISR/community treatment)	Andrews: ISR with required community treatment and supervision is adequate and should substitute for commitment	County: Andrews’ plan is vague; no program willing to accept him while civilly committed; denial undermines treatment success	Court: affirmed—Andrews failed to prove by clear and convincing evidence a less-restrictive program was available and appropriate
Challenge to constitutionality of MCTA (facial and as-applied) based on Karsjens decisions	Andrews: relies on Karsjens federal rulings finding parts of MSOP framework unconstitutional	County: federal remedial orders were stayed; Karsjens I did not invalidate initial commitment; Minnesota precedent supports statute	Court: affirmed—Karsjens interlocutory orders were stayed and do not entitle Andrews relief; MCTA commitment procedures upheld

In re Linehan, 518 N.W.2d 609 (Minn. 1994) (Linehan factors and SDP evaluation framework)
In re Linehan, 594 N.W.2d 867 (Minn. 1999) (Linehan IV) (MCTA initial-commitment procedures comply with substantive due process)
In re Civil Commitment of Stone, 711 N.W.2d 831 (Minn. App. 2006) (course-of-conduct can include unconvicted acts and need not be recent)
In re Civil Commitment of Navratil, 799 N.W.2d 643 (Minn. App. 2011) (standard of review for commitment findings)
In re Civil Commitment of Ince, 847 N.W.2d 13 (Minn. 2014) (district-court findings required to allow meaningful appellate review on less-restrictive-alternative issue)
In re Robb, 622 N.W.2d 564 (Minn. App. 2001) (burden on respondent to prove less-restrictive alternative by clear and convincing evidence)
Karsjens v. Piper, 109 F. Supp. 3d 1139 (D. Minn. 2015) (federal district court remedial rulings regarding MSOP conditions; remedial orders stayed on appeal)
Nken v. Holder, 556 U.S. 418 (2009) (federal appellate authority to stay lower-court orders pending appeal)