Senty-Haugen, In re

Decision Date20 August 1998
Docket NumberNo. C9-96-1095,SENTY-HAUGEN,C9-96-1095
Citation583 N.W.2d 266
PartiesIn re Arthur Dale
CourtMinnesota Supreme Court

Syllabus by the Court

Under the current statutory scheme, a person committed as a sexual psychopathic personality or a sexually dangerous person under Minn.Stat. §§ 253B.02, subds. 18a, 18b; 253B.185 (1996) has no statutory right to receive treatment in the program that is the least restrictive alternative.

Steven R. Kufus, St. Paul, for appellant.

Susan Gaertner, Ramsey County Atty., Steven R. Pfaffe, Asst. Ramsey County Atty., St. Paul, for respondent.

Heard, considered, and decided by the court en banc.

OPINION

GARDEBRING, Justice.

Arthur Dale Senty-Haugen appeals a decision by the trial court, affirmed by the court of appeals, holding that the statutory provisions governing commitment as a sexual psychopathic personality or sexually dangerous person (SPP/SDP) do not entitle him to receive treatment from the least restrictive alternative program if no funding exists to pay for that treatment. Ramsey County petitioned to have Senty-Haugen, a convicted sex offender, committed as SPP/SDP under Minn.Stat. §§ 253B.02, subds. 18a, 18b; 253B.185 (1996). At a preliminary hearing, Senty-Haugen stipulated that he met the requirements for commitment under the SPP/SDP provisions, and in return, he was permitted to seek admission to and funding for a sexual offender treatment program called Alpha House, a program less restrictive than a state secure treatment facility. After Senty-Haugen unsuccessfully attempted to join as parties several governmental agencies in an effort to compel them to fund his placement at Alpha House, the court ordered that Senty-Haugen be indefinitely committed to a state secure treatment facility for sexual offenders. The court of appeals affirmed.

While we agree that Senty-Haugen has no right to treatment at Alpha House, we base our decision on a different theory than the court of appeals. Specifically, we conclude that, unlike the provisions relating to commitment for mental illness, mental retardation or chemical dependence, the statutory provisions governing SPP/SDP commitments contain no requirement that treatment be in the least restrictive setting. Therefore, we affirm the court of appeals.

Senty-Haugen was convicted in July 1993 of seven counts of criminal sexual conduct involving minors and served 18 months in prison. In November 1994, several weeks before his scheduled release, Ramsey County filed a petition seeking to have him indefinitely committed as SPP/SDP under Minn.Stat. §§ 253B.02, subds. 18a, 18b; 253B.185.

At a pre-trial conference in February 1995, Senty-Haugen agreed to admit virtually all of the allegations in the commitment petition, to waive his right to a hearing, and to stipulate that he met the requirements for commitment under the SPP/SDP provisions. As part of the stipulation, the parties agreed that Senty-Haugen could seek admission to a program such as Alpha House, a private, highly structured, community-based treatment facility for nonviolent pedophiles that was less restrictive than a state secure treatment facility. Nevertheless, the stipulation stated that the court was not required to commit Senty-Haugen to Alpha House or any other less restrictive program, even if he were admitted and had full support from the mental health professionals who had examined him.

In March, Alpha House's intake director informed Senty-Haugen that he would be accepted into its program if funding was available to pay for his treatment, but that there was an 8- to 10-month waiting list for an opening. A psychologist and a psychiatrist from a state secure treatment facility both agreed that Senty-Haugen was an acceptable candidate for treatment at Alpha House. After considering this testimony, the district court stated that Alpha House might in fact be a better program for Senty-Haugen than treatment at a state secure treatment facility. The issue arose, however, as to who would pay for treatment at Alpha House. The court postponed the final commitment hearing for 30 days to allow Senty-Haugen to pursue funding alternatives.

Attempting to secure funding for his treatment at Alpha House, Senty-Haugen filed a motion seeking to join the Ramsey County Department of Corrections, the Minnesota Commissioner of Human Services, and several other government agencies as necessary parties to the commitment proceeding. The Ramsey County Department of Corrections and the Minnesota Commissioner of Human Services each denied responsibility to pay for Senty-Haugen's treatment at Alpha House.

The district court denied Senty-Haugen's motion, concluding that none of the government agencies that Senty-Haugen sought to join had a statutory obligation to fund treatment at Alpha House. In an order dated March 29, 1996, the court held that Ramsey County had proved by clear and convincing evidence that Senty-Haugen was SPP/SDP, that commitment was necessary for the protection of society, and that there was no reasonable alternative to commitment. It committed Senty-Haugen indefinitely to the sexual psychopathic personality treatment program at a state secure treatment facility. The court made detailed findings of fact in its order, but did not mention Alpha House or discuss the feasibility of placing Senty-Haugen in a less restrictive alternative to the state secure treatment facility.

Senty-Haugen appealed, asserting that the district court erred first in finding that Ramsey County was not obligated to fund treatment at Alpha House, and second, in failing to make sufficient findings regarding the availability of less restrictive treatment programs. The court of appeals affirmed. While this appeal was pending, Alpha House's executive director informed the Minnesota Attorney General's Office that its program no longer admitted persons who had been committed as SPP/SDP.

On appeal to this court, Senty-Haugen argues that the district court erred in failing to place him in the least restrictive treatment program--that is, Alpha House--when there was clear and convincing evidence that Alpha House was an acceptable alternative to commitment to a state secure treatment facility and that funding was available. The lower court decisions as well as the parties' briefs contain detailed considerations of which government agency might be required to pay for Senty-Haugen's treatment in a facility determined to be less restrictive than a state secure treatment facility. Although we affirm, we do so on a different theory. See, e.g., Brecht v. Schramm, 266 N.W.2d 514, 520 (Minn.1978) (holding that a lower court's decision should not be overturned if it may be affirmed on a different theory). Our reading of the relevant statutes suggests that, unlike commitment procedures for persons with mental illness, mental retardation or chemical dependency, Minn.Stat. § 253B.185, governing SPP/SDP commitments, simply does not require that such commitments be made to the least restrictive treatment program. 1

We begin with an examination of the complex statutory scheme that provides both substantive standards and procedural requirements for the civil commitment of Minnesota citizens. See Minn.Stat. ch. 253B (1996). We review such questions of statutory interpretation de novo. Lolling v. Midwest Patrol, 545 N.W.2d 372, 375 (Minn.1996). The statutory scheme for commitment varies considerably depending upon the type of mental illness or other condition that triggers the state's intervention, reflecting the legislature's various approaches to balancing individual rights against the needs and obligations of the larger society.

In general, commitments are of three basic types: (1) those involving persons who are mentally ill, mentally retarded or chemically dependent, and governed generally by the definitions contained in Minn.Stat. § 253B.02 and the procedures contained in §§ 253B.07 -.09; (2) those involving persons deemed "mentally ill and dangerous," as defined in Minn.Stat. § 253B.02, subd. 17, and governed by the procedures contained in Minn.Stat. § 253B.18; and (3) those involving persons sought to be committed as "sexual psychopathic personalities" or "sexually dangerous persons" under Minn.Stat. § 253B.02, subds. 18a, 18b; and governed by the procedures contained in section 253B.185. The standards and procedures governing commitments for the first category of persons--those who are mentally ill, mentally retarded or chemically dependent--are the most deferential to individual personal rights and contain the greatest degree of due process protection. In keeping with that philosophical approach, only the provisions governing commitment of mentally ill, mentally retarded or chemically dependent persons contain a provision that, upon a finding that there is no suitable alternative to judicial...

To continue reading

Request your trial
59 cases
  • State v. Carter, No. A03-1215.
    • United States
    • Minnesota Supreme Court
    • June 9, 2005
    ...N.W.2d 884, 888 (Minn.1981) (deferring the constitutional issue because conviction was reversed on other grounds); In re Senty-Haugen, 583 N.W.2d 266, 269 n. 3 (Minn.1998) ("It is well-settled law that courts should not reach constitutional issues if matters can be resolved When examining w......
  • State v. Jackson
    • United States
    • Minnesota Supreme Court
    • December 6, 2007
    ...rulings if an issue can be decided on other grounds. See State v. Bourke, 718 N.W.2d 922, 926 (Minn.2006); In re Senty-Haugen, 583 N.W.2d 266, 269 n. 3 (Minn.1998) ("It is well-settled law that courts should not reach constitutional issues if matters can be resolved otherwise."). The majori......
  • State v. Jordan
    • United States
    • Minnesota Supreme Court
    • December 6, 2007
    ...analysis if an issue can be decided without reaching a constitutional question. See Bourke, 718 N.W.2d at 926; In re Senty-Haugen, 583 N.W.2d 266, 269 n. 3 (Minn.1998) ("It is well-settled law that courts should not reach constitutional issues if matters can be resolved otherwise."). The ma......
  • Ninetieth Minn. State Senate v. Dayton
    • United States
    • Minnesota Supreme Court
    • November 16, 2017
    ...statutes to avoid a constitutional confrontation, including "to avoid potential separation of powers problems"); In re Senty-Haugen, 583 N.W.2d 266, 269 n.3 (Minn. 1998) ("It is well-settled law that courts should not reach constitutional issues if matters can be resolved otherwise.").Here,......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT