Supreme Court Digest: Feb. 1, 2023

Civil

Civil Commitment

Qualified Immunity

The Minnesota Commitment Appeals Panel (CAP) ordered two patients in the Minnesota Sex Offender Program (MSOP), respondents, to be transferred to Community Preparation Services (CPS)—a reduction in custody. Respondents claimed that the Commissioner of the Department of Human Services and the Executive Director of the MSOP violated their due process rights by delaying transfer of respondents to CPS for over 2 years following the CAP transfer orders and sought relief under 42 U.S.C. § 1983. The state officials sought to invoke qualified immunity against respondents’ section 1983 claims. The District Court concluded respondents each sufficiently alleged a violation of their Fourteenth Amendment due process rights to a transfer to CPS within a reasonable amount of time following a CAP transfer order. The District Court also determined, however, that qualified immunity shielded the state officials because the right to transfer to CPS within a reasonable time of the CAP transfer orders was not clearly established when the CAP transfer orders were issued. Consequently, the District Court granted the officials’ motions to dismiss. In affirming the District Court, the Court of Appeals assumed, without deciding, that respondents had sufficiently alleged violations of their due process rights. But the Court of Appeals agreed with the District Court that the right to a transfer within a reasonable time of the CAP transfer orders was not clearly established.

The Supreme Court held that respondent MSOP patients had a clearly established right to transfer to Community Preparation Services within a reasonable time following issuance of a Minnesota Commitment Appeals Panel transfer order. What amount of time is reasonable in any given set of circumstances is an issue of fact to be determined by the District Court. Reversed and remanded.

A21-0042, A21-0043 McDeid v. Johnston (Court of Appeals)

Criminal

Postconviction Relief

Time Bar

In 2003, a jury found petitioner guilty of several offenses, including first-degree felony murder, and attempted first-degree premeditated murder. In this appeal, petitioner asserted that the District Court abused its discretion by summarily denying his second postconviction petition, which alleged that the jury foreperson was biased because she and one of the potential witnesses worked at the same place. The Supreme Court held that petitioner’s postconviction claims were barred by the 2-year time limit in Minn. Stat. § 590.01, subd. 4(a), and did not satisfy the interests-of-justice exception in Minn. Stat. § 590.01, subd. 4(b)(5). Affirmed.

A22-0662 White v. State (St. Louis County)