State v. T.O., 793 N.W.2d 204

T.O. was civilly committed as a sexually dangerous individual in 2005.
In February 2010, T.O. filed a petition for discharge to review his status.
Two experts evaluated T.O.: the state expert deemed him sexually dangerous; the independent expert did not.
In August 2010, the district court held a hearing and issued an order that T.O. remains sexually dangerous and in DHS custody.
The district court’s findings were deemed insufficient under N.D.R.Civ.P. 52(a); the court did not provide the evidentiary basis for its decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s findings comply with Rule 52(a).	T.O. argues findings are conclusory and lack factual basis.	State contends the record supports the court’s decision.	No; remand for sufficient findings.
Whether Madison v. North Dakota Dep’t of Transp. should govern reversal for systemic disregard.	Madison supports reversal for systemic law disregard.	Madison does not apply to this case.	Declined; remand for proper findings under 52(a).
Is the record enough to sustain continued commitment once findings are provided?	Record may support continued commitment if findings are detailed.	Record supports continued commitment based on evidence.	Not determined on this record; requires remand for proper findings.

In re R.A.S., 756 N.W.2d 771 (2008 ND) (requires detailed factual findings and credibility determinations)
In re J.S., 621 N.W.2d 582 (2001 ND) (integral to why detailed findings are needed)
Madison v. North Dakota Dep’t of Transp., 503 N.W.2d 243 (1993 ND) (reversal for systemic disregard of law)