In re Civ. Commitment of Johnson, 931 N.W.2d 649, 657 (Minn.App. 2019), rev. denied (Minn. Sept. 17, 2019). We review ineffective-assistance-of-counsel claims de novo.
In commitment matters, ineffective-assistance-of-counsel claims are examined in the same manner as criminal cases. See In re Civil Commitment of Johnson, 931 N.W.2d 649, 657 (Minn. App. 2019) ("This court analyzes ineffective-assistance-of-counsel claims in civil-commitment cases under the Strickland standard that applies in criminal cases."), review denied (Minn. Sept. 17, 2019).
We review a district court's decision to vacate judgment for an abuse of discretion. In re civil commitment of Johnson, 931 N.W.2d 649, 655 (Minn. App. 2019), review denied (Minn. Sept. 17, 2019).
A district court's denial of a rule 60.02 motion is reviewed for an abuse of discretion. In re Civil Commitment of Johnson, 931 N.W.2d 649, 655 (Minn. App. 2019), review denied (Minn. Sept. 17, 2019).
In re Civ.Commitment of Johnson, 931 N.W.2d 649, 657 (Minn.App. 2019), rev. denied (Minn. Sept. 17, 2019). In the civil-commitment context, we analyze ineffective-assistance-of-counsel claims using "the analytical framework ordinarily used in criminal cases when applying the Sixth Amendment right to counsel."
A person who is indeterminately committed as an SDP or an SPP may bring an ineffective assistance of counsel claim. In re Civil Commitment of Johnson, 931 N.W.2d 649, 657 (Minn.App. 2019), rev. denied (Minn. Sept. 17, 2019).
In re Civ. Commitment of Johnson, 931 N.W.2d 649, 657 (Minn.App. 2019) (appeal from civil commitment).
"It is an appellant's burden to provide any transcript necessary for appellate review." In re Commitment of Johnson, 931 N.W.2d 649, 658 (Minn.App. 2019); Minn. R. Civ. App. P. 110.02, subd. 1(a). Because father did not provide this court with transcripts of the pretrial hearings, we do not have a record of the discussions that occurred in connection with the requests, including the district court's responses.
We review a district court's denial of a rule 60.02 motion for an abuse of discretion. In re Civil Commitment of Johnson, 931 N.W.2d 649, 655 (Minn. App. 2019), review denied (Minn. Sept. 17, 2019).
We analyze ineffective-assistance-of-counsel claims in civil-commitment cases under the Strickland standard. In re Civil Commitment of Johnson, 931 N.W.2d 649, 657 (Minn. App. 2019). And we review these claims de novo.