Stabnow v. Lourey
- Paul Magnuson
- 0:19-cv-01539
- U.S. District Court · District of Minnesota
- 4
In Stabnow v. Lourey, Judge Magnuson required state-court review first, dismissed the petitions without prejudice, denied summary judgment, and denied a certificate of appealability.
Robert Lee Stabnow and his federal challenges to his Minnesota civil commitment; the order required him to present the claims to Minnesota state courts before seeking federal relief.
What happened
Robert Lee Stabnow, who is committed to the Minnesota Sex Offender Program, filed a federal petition seeking to vacate his commitment based on alleged constitutional violations. He argued that Minnesota’s commitment laws were unconstitutional and that state courts could not fairly review his claims.
The court rejected his challenge to the commitment laws based on binding Eighth Circuit precedent. It also concluded that his allegations about state-court bias were unsupported, that his described treatment did not amount to cruel and unusual punishment, and that he had to present his claims to Minnesota courts before seeking federal relief.
In Stabnow v. Lourey, Judge Paul A. Magnuson adopted the magistrate judge’s recommendation, denied and dismissed the petition and amended petition without prejudice, denied Stabnow’s motion for summary judgment, and ruled that no certificate of appealability would issue.
The detailed version
- Stabnow v. Lourey · No. 0:19-cv-01539
- Paul Magnuson
- Oct. 11, 2019
Background
Robert Lee Stabnow is committed to the Minnesota Sex Offender Program. He had previously challenged his commitment several times in state court. In this federal case, he sought a declaratory judgment vacating his commitment for alleged constitutional violations. The court considered a magistrate judge’s Report and Recommendation, which recommended denying Stabnow’s motion for summary judgment and dismissing the petition and amended petition without prejudice as to one claim and with prejudice as to another. Stabnow objected.
Claims and analysis
Stabnow clarified that he was challenging the constitutionality of the laws governing his commitment, both facially—meaning in all applications—and as applied to him. The court stated that the Eighth Circuit had already rejected that challenge and that the district court was bound by that ruling. The court also rejected Stabnow’s argument that Minnesota’s elected judges, legislators, and executive officials were too politically motivated to provide a fair review. It said that this argument relied on innuendo and supposition and would not support a presumption that state judges were biased.
The court concluded that Stabnow had to present his claims to the state courts first. It also addressed his arguments that commitment to the Minnesota Sex Offender Program was punishment violating the constitutional protection against being punished twice for the same conduct and that the conditions violated the Eighth Amendment’s ban on cruel and unusual punishment. The court stated that the treatment Stabnow described, even if accepted as true, did not reach the level of an Eighth Amendment violation. It said that any claim under the Minnesota Constitution had to be decided by the state courts first.
Disposition
The court adopted the Report and Recommendation after reviewing Stabnow’s specific objections. It ordered that the petition and amended petition were denied and dismissed without prejudice. It denied Stabnow’s motion for summary judgment. It also ruled that a certificate of appealability would not issue because Stabnow had not made a substantial showing that a constitutional right had been denied.
Classification note
This is a mixed ruling: the court disposed of some challenges on threshold grounds, including failure to first use state-court remedies and the time bar identified in the recommendation, while also addressing the substance of the constitutional challenge to the commitment laws and the alleged Eighth Amendment violation.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.