Karsjens v. Piper (8th Cir. 2017)

Karsjens v. Piper, 845 F.3d 394 (8th Cir. 2017)

Nature of Case: Federal § 1983 suit filed by individuals who were subjected to sex offense civil commitment pursuant to Minnesota’s Civil Commitment and Treatment Act. Suit contained various facial and as-applied challenges to their confinement violated constitution.

District court conducted a lengthy, six-week bench trial, at the conclusion of which it found that the Act, and the state’s implementation of it, did violate the Plaintiffs’ due process rights on the grounds that the Act:

• Did not require periodic risk assessment, thereby subjecting those so confined to longer periods of confinement than necessary;
• Contained no provision by which individuals confined could petition for judicial review outside of statutory discharge;
• Made the burden for obtaining discharge from the confinement more onerous than admission to it;
• Shifts the burden from the state to the individual to petition for reduction in custody;
• Makes reference to less restrictive alternatives than confinement, even where no less restrictive alternatives are in fact available;
• Does not require the state to take any affirmative action when individuals no longer meet the criteria for civil commitment.

The district court entered an injunctive order, and Minnesota state authorities appealed to the Eighth Circuit Court of Appeals.

Holding:  Eighth Circuit held that the district court applied the incorrect standard of review when evaluating the Plaintiff’s facial and as-applied claims. Court held that rational-basis test was the correct standard for the facial challenges (as opposed to strict scrutiny applied by the district court), and found that when reviewed under the more deferential standard, the Plaintiffs’ facial claims failed. Furthermore, Court found that the district court’s analysis of the as-applied challenges was flawed and that they did not need the conscience-shocking standard to prevail on an as applied due process challenge. Court remanded the case to the district court for further proceedings.

Plaintiffs petitioned United States Supreme Court for certiorari, which the Court denied on October 2, 2017.

Note: The 8th Circuit Court of Appeals has subsequently ruled on this case in Karsjens II