Supreme Court Digest: March 11, 2026

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Civil

Civil Commitment

Involuntary Treatment

This case required a decision as to whether the legal test that Minnesota courts apply when ruling on petitions to administer involuntary intrusive treatments such as electroconvulsive therapy (ECT) to civilly committed individuals—the framework established in Price v. Sheppard, 239 N.W.2d 905 (Minn. 1976), and affirmed in Jarvis v. Levine, 418 N.W.2d 139 (Minn. 1988)—adequately addresses the statutory language setting forth a means for obtaining consent to any “treatment necessary to preserve the life or health of any committed patient” in Minn. Stat. § 253B.03, subd. 6(b). Since 1988, District Courts have decided such petitions using the Price/Jarvis balancing test, which requires courts to determine if the intrusive treatment is both “necessary and reasonable.” In this case, appellant, who is civilly committed, appealed a District Court order authorizing involuntary ECT administration pursuant to this statute after applying the Price/Jarvis balancing test. The Court of Appeals affirmed.

The Supreme Court held that Price/Jarvis balancing test, which requires a District Court to find that an intrusive treatment is both necessary and reasonable before it can be administered to a civilly committed patient, adequately addresses whether the intrusive treatment is a “treatment necessary to preserve the life or health of any committed patient” under Minn. Stat. § 253B.03, subd. 6(b). Affirmed.

A24-0067 In re Civ. Commitment of Graeber (Court of Appeals)

Domestic Relations

Child Protection; CHIPS

On April 9, 2022, twins were born with severe medical problems. They are both eligible for membership in the Miskwaagamiiwi-zaaga’iganing Tribe, also known as Red Lake Nation. Immediately following their births, respondent Human Services of Faribault and Martin Counties filed a petition for a Child in Need of Protection or Services (CHIPS) on behalf of both children. Following an emergency protective care hearing, the children’s interim legal care, custody, and control were transferred from their biological mother, respondent, to the County. Upon their discharge from the hospital, both twins were placed in emergency foster care with appellant-foster parents. After approximately a year and a half, appellants learned the twins were scheduled to move imminently and live with one of their maternal relatives. In the twins’ CHIPS proceedings, appellants filed an emergency motion for permissive intervention, a petition for third-party custody, and a motion to stay the move to the maternal relative. The District Court denied the motions for permissive intervention and for a stay of the move and dismissed the petition for third-party custody. The District Court did so without addressing appellants’ argument that the Indian Child Welfare Act (ICWA) and the Minnesota Indian Family Preservation Act (MIFPA) violate the Fifth and Fourteenth Amendments’ guarantees of equal protection. Appellants appealed. The Court of Appeals affirmed in part, reversed in part, and remanded for further proceedings on the issues of permissive intervention and third-party custody, and review was granted. While the issue of ICWA’s and MIFPA’s constitutionality remained pending before the Supreme Court, the District Court reconsidered the permissive intervention motion and the third-party custody petition based on the Court of Appeals’ remand instructions. The District Court again denied permissive intervention and dismissed the petition for third-party custody. Appellants appealed the denials to the Court of Appeals and then filed a petition for accelerated review.

The Supreme Court held that (1) the District Court did not abuse its discretion when it denied appellants’ motion to permissively intervene in a CHIPS action in juvenile court pursuant to Minn. R. Juv. P. 34.02; (2) a petition for third-party custody filed in juvenile court is non-cognizable and is instead properly construed as a petition for a transfer of legal and physical custody, which may only be filed by a party to the juvenile court action; and (3) a holding in a Court of Appeals opinion that is advisory in nature and goes beyond the narrow issues implicated in the orders giving rise to the appeal falls outside the appropriate scope of appellate review and warrants this court, in the exercise of its supervisory authority, vacating that portion of the opinion. Affirmed in part and vacated in part.

A23-1762, A24-1296 In re Welfare of Children of L.K. (Court of Appeals & Martin County)

Property Tax

Valuation

In this appeal from the Tax Court, relator-taxpayer raised several challenges to respondent-county’s assessment of residential property taxes. Relator sued the county and two county officials in District Court, alleging that they had overvalued relator’s residential property and had discriminated against relator during the property tax valuation process. Upon the motion of the County and the county officials, the District Court transferred the case to the Tax Court. Relator challenged the transfer, but the Tax Court denied relator’s requests to return the case to the District Court. The Tax Court also dismissed the four enumerated counts in relator’s complaint on the basis that Minn. Stat. ch. 278 provides the exclusive remedy for relator’s claims. Following a trial in the Tax Court regarding the 2022 valuation of the property under chapter 278, the Tax Court concluded that relator failed to overcome the statutory presumption that the County’s valuation was valid and found that the value of the subject property was the assessed value of $849,000. Based on this determination, the Tax Court dismissed relator’s claim regarding the 2022 valuation of the property.

The Supreme Court held that (1) the Tax Court had subject matter jurisdiction over the taxpayer’s case because each of the counts in the taxpayer’s complaint concerned the valuation of the subject property or the property tax assessment process, which are claims under Minnesota state tax law; (2) the Tax Court did not err in dismissing the four counts in the taxpayer’s complaint because each of those counts was within the scope of Minn. Stat. § 278.01, which provides the exclusive remedy for such claims; and (3) the Tax Court did not err when it dismissed the taxpayer’s valuation claim at trial because the taxpayer did not overcome the statutory presumption of validity of the county’s assessed value of the subject property. Affirmed.

A25-0497 Lockhart v. Hennepin County (Tax Court)