Samantha Raye Meyer v. Robert J. Harley, A16-1304

Background

Meyer petitioned for a harassment restraining order (HRO) in 2016, alleging Harley sexually assaulted her in 2011–2012 and engaged in harassment (waiting outside dorm/buildings, unwanted communications, threats).
Meyer had not had contact with Harley since 2011–2012 and testified she feared he might try to contact her after learning he took a job in the building where she works.
Employer verified Harley took the job; Harley denied knowing Meyer's workplace and denied any contact since 2011–2012.
The district court admitted emails from 2012 over Harley’s objection, found sexual-assault allegations unproven, but concluded there were reasonable grounds to believe Harley harassed Meyer in 2011–2012 and issued an HRO.
On appeal, Harley argued the court made insufficient factual findings, lacked reasonable grounds to issue the HRO, and erred in admitting the emails. The Court of Appeals reviewed findings and the legal sufficiency of the HRO.

Issues

Issue	Meyer’s Argument	Harley’s Argument	Held
Were the district court’s factual findings sufficient?	Findings and credibility determinations support the HRO; remand unnecessary.	Findings are too vague to identify which facts supported the order.	Findings were adequate because the court’s conclusions allow inference of the facts and credibility determinations.
Did reasonable grounds exist to issue an HRO based on harassment from acts four years earlier?	Past harassment and Meyer’s fear of contact (upon learning of Harley’s new job) justify HRO.	Four years of no contact defeats an objectively reasonable belief of present substantial adverse effect; Kass controlling.	No—reasonably objective belief of present substantial adverse effect was not shown; HRO reversed.
Does the harassment statute require present intent or present harm (as interpreted in Kass)?	The harassment statute’s plain language does not require proof of present intent; past conduct can support relief.	Kass suggests restraining orders shouldn’t issue solely on remote past incidents without present harm.	Kass is distinguishable; statute lacks present-harm requirement, but on these facts absence of contact for four years made the belief unreasonable.
Were evidentiary rulings (admission of emails) reversible error?	Admission permissible to show unwanted communications.	Admission prejudiced Harley; should be excluded.	Court did not decide because it reversed on sufficiency of grounds; evidentiary challenge not reached.

Key Cases Cited

Mechtel v. Mechtel, 528 N.W.2d 916 (Minn. App. 1995) (trial court must make specific findings for protective orders)
Crowley Co. v. Metro. Airports Comm’n, 394 N.W.2d 542 (Minn. App. 1986) (findings required to permit meaningful appellate review)
Welch v. Comm’r of Pub. Safety, 545 N.W.2d 692 (Minn. App. 1996) (inference of omitted findings may avoid remand)
Grein v. Grein, 364 N.W.2d 383 (Minn. 1985) (no remand where existing findings and record render remand pointless)
Peterson v. Johnson, 755 N.W.2d 758 (Minn. App. 2008) (abuse-of-discretion review for HROs; legal question of harassment elements reviewed de novo)
Kush v. Mathison, 683 N.W.2d 841 (Minn. App. 2004) (district court findings not set aside unless clearly erroneous)
Dunham v. Roer, 708 N.W.2d 552 (Minn. App. 2006) (elements for HRO: objectively unreasonable conduct and objectively reasonable belief of substantial adverse effect)
Kass v. Kass, 355 N.W.2d 335 (Minn. App. 1984) (construing Domestic Abuse Act to require present harm or intent; restraining order not justified solely by a distant sighting)
Anderson v. Lake, 536 N.W.2d 909 (Minn. App. 1995) (harassment statute and Domestic Abuse Act sufficiently similar for some precedent to be considered)
Witchell v. Witchell, 606 N.W.2d 730 (Minn. App. 2000) (context matters when assessing whether statements constitute harassment)