Opinion
A21-0842
04-05-2022
In the Matter of the Civil Commitment of: Wayne Carl Nicolaison.
Hennepin County District Court File No. 27-P7-91-034391
Considered and decided by Reyes, Presiding Judge; Johnson, Judge; and Cochran, Judge.
ORDER OPINION
JEANNE M. COCHRAN JUDGE.
BASED ON THE FILE, RECORD, AND PROCEEDINGS, AND BECAUSE:
1. In 1992, appellant Wayne Nicolaison was indeterminately civilly committed as a sexual psychopathic personality.
Nicolaison was committed as a psychopathic personality under Minn. Stat. § 526.10 (1990). In 1994, the legislature enacted the sexually-dangerous-person and sexual-psychopathic-personality provisions. 1994 Minn. Laws 1st Spec. Sess. ch. 1, art. 1, §§ 2-7, at 5-9. These provisions renamed psychopathic personalities as sexual psychopathic personalities but did not substantively change the previous provisions. Id., § 5, at 8. Nicolaison is therefore governed by the provisions applicable to sexual psychopathic personalities. See Minn. Stat. §§ 253D.02, subd. 15, .07 (2020) (providing current definition and outlining proceedings for sexual psychopathic personalities).
2. In September 2020, Nicolaison moved the district court, under Minnesota Rule of Civil Procedure 60.02(d), to vacate his 1992 judgment of commitment, arguing that the judgment was void because the district court lacked subject-matter jurisdiction over the commitment. Nicolaison also argued that he could not be civilly committed because he is not mentally ill and because his indeterminate civil commitment violates his right to equal protection under the Fourteenth Amendment of the United States Constitution. The district court rejected Nicolaison's arguments and denied his motion to vacate in a May 2021 order. Nicolaison appeals.
3. We review the district court's denial of a rule 60.02 motion to vacate for an abuse of discretion. In re Civ. Commitment of Johnson, 931 N.W.2d 649, 655 (Minn.App. 2019), rev. denied (Minn. Sept. 17, 2019). We review jurisdictional questions de novo. Bode v. Minn. Dep't of Nat. Res., 612 N.W.2d 862, 866 (Minn. 2000).
4. A district court may relieve a party from a final judgment when the judgment is void. Minn. R. Civ. P. 60.02(d). A judgment is void for purposes of rule 60.02(d) if the court that issued the judgment lacked jurisdiction over the subject matter. Bode, 612 N.W.2d at 866; see also Matson v. Matson, 310 N.W.2d 502, 506 (Minn. 1981) ("A void judgment is one rendered in the absence of jurisdiction over the subject matter or the parties."). Subject-matter jurisdiction is defined as a court's "authority to hear and determine a particular class of actions" as well as "the particular questions the court assumes to decide." Irwin v. Goodno, 686 N.W.2d 878, 880 (Minn.App. 2004) (quotation omitted).
5. It is well established that state courts have subject-matter jurisdiction over civil commitments. In re Civ. Commitment of Beaulieu, 737 N.W.2d 231, 237 (Minn.App. 2007); see also In re Ivey, 687 N.W.2d 666, 669 (Minn.App. 2004) ("The district court has subject matter jurisdiction over judicial commitments, including commitments of a person as a sexual psychopathic personality or as a sexually dangerous person."), rev. denied (Minn. Dec. 22, 2004). Nicolaison has not shown that the district court lacked subject-matter jurisdiction over the 1992 judgment of commitment. Thus, the judgment is not void under rule 60.02(d).
6. Additionally, to the extent that Nicolaison seeks to be discharged from commitment, he cannot obtain that relief using a rule 60.02 motion. The Commitment Act provides the exclusive remedy for persons committed as sexual psychopathic personalities to seek a discharge or transfer. In re Civ. Commitment of Lonergan, 811 N.W.2d 635, 642 (Minn. 2012).
7. Nicolaison raises several additional arguments in his appellate brief, some of which he also argued in his motion to vacate. He argues that he cannot be civilly committed because he does not meet the definition of "mentally ill," his prior counsel was ineffective, other states do not impose civil commitment under the same criteria, and the civil commitment violates his constitutional due-process rights. None of these arguments show that the 1992 judgment of commitment is void, as necessary to warrant relief under rule 60.02(d). See Majestic Inc. v. Berry, 593 N.W.2d 251, 257 (Minn.App. 1999) ("[A] judgment is not void merely because it is erroneous." (quotation omitted)), rev. denied (Minn. Aug. 18, 1999). As such, we need not address these arguments. The district court properly dismissed Nicolaison's rule 60.02(d) motion to vacate.
IT IS HEREBY ORDERED:
1. The district court's order is affirmed.
2. Pursuant to Minn. R. Civ. App. P. 136.01, subd. 1(c), this order opinion is nonprecedential, except as law of the case, res judicata, or collateral estoppel.