In re Lonergan
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Peter Lonergan and Robert Kunshier were both indeterminately civilly committed to the Minnesota sex offender program. Lonergan and Kunshier each sought relief from his commitment by filing a pro se motion under Minn. R. Civ. P. 60.02. After the district court denied the motions, both Lonergan and Kunshier appealed. The court of appeals affirmed the denial of Lonergan's motion, holding that as a sexually dangerous person, Lonergan could not use Rule 60.02 to seek a discharge from his indeterminate commitment or to make a constitutional challenge to the adequacy of his treatment at the sex offender program. The court also affirmed the denial of Kunshier's motion, concluding that Rule 60.02 may not be used to seek any relief from an indeterminate civil commitment order. The Supreme Court reversed in part, holding (1) the court of appeals erred in Kunshier's case when it articulated a blanket prohibition on use of Rule 60.02 motions by patients indeterminately committed as sexually dangerous persons or sexual psychopathic personalities; and (2) Lonergan's claims warranted reconsideration in light of this decision. Remanded.
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