Favors v. Kneisel

902 N.W.2d 92, 2017 WL 4228715
CourtCourt of Appeals of Minnesota
DecidedSeptember 25, 2017
DocketA17-0506
StatusPublished
Cited by2 cases

This text of 902 N.W.2d 92 (Favors v. Kneisel) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Favors v. Kneisel, 902 N.W.2d 92, 2017 WL 4228715 (Mich. Ct. App. 2017).

Opinion

OPINION

REILLY, Judge

Appellant Joseph Anthony Favors challenges the district court’s dismissal of his claim against respondent-employees of the Minnesota Department of Human Services, arguing that the district court erred by holding that (1) Minnesota Statutes section 144.651 does not create a private cause of action and (2) appellant cannot establish a substantive due-process violation. Because Minnesota Statutes section 144.651 does not create a private cause of action and appellant failed to assert a cognizable substantive due-process claim, we affirm.

FACTS

Appellant Joseph Anthony Favors is civilly committed to the Minnesota Sex Offender Program (MSOP) for an indeterminate period of time as a sexually dangerous person and a sexually psychopathic person. In April 2016, appellant filed a complaint against respondent-employees of the Minnesota Department of Human Services/MSOP, alleging that respondents violated his constitutional and statutory rights under 42 U.S.C. § 1983 and Minnesota Statutes section 144.651, by denying his request for a cassette recorder. Respondents sought dismissal of the complaint for failure to state a claim upon which relief may be granted, arguing that section 144.651 does not create a private cause of action and that appellant failed to support his constitutional claim. The district court agreed and dismissed appellant’s claims with prejudice; this appeal follows.

ISSUES

I. Does Minnesota Statutes section 144.651 create a private cause of action?

II. Did appellant state a viable substantive due-process claim?

DECISION

We review de novo the dismissal of a complaint under Minnesota Rule of Civil Procedure 12.02(e) for failure to set forth a legally sufficient claim for relief. Graphic Commc’ns Local 1B Health & Welfare Fund A v. CVS Caremark Corp., 850 N.W.2d 682, 692 (Minn. 2014). In so doing, we accept the facts alleged in the complaint as true and construe all reasonable inferences in favor of the party seeking relief. Id. But we will uphold a dismissal order “if it appears to a certainty that no facts, which could be introduced consistent with the pleading, exist which would support granting the relief demanded.” Finn v. All. Bank, 860 N.W.2d 638, 653 (Minn. 2015) (quotation omitted).

I. The district court did not err in dismissing appellant’s complaint with prejudice for failure to state a claim upon which relief may be granted because the Minnesota Patients’ Bill of Rights, Minnesota Statutes section 144.651, does not create a private cause of action.

Appellant argues that respondents violated his rights under the Minnesota Patients’ Bill of Rights, Minnesota Statutes section 144.651,1 by denying his request for a cassette recorder. The district court dismissed' his claim on the ground that section 144.651 does not create a private cause of action. Whether a statute creates a private cause of action is a question of statutory interpretation reviewed de novo. Becker v. Mayo Found., 737 N.W.2d 200, 207 (Minn. 2007). A statute gives rise to a private cause of action only if “the language of the statute is explicit or it can be determined by clear implication.” Id. We consider three factors in our analysis:

(1) whether the plaintiff belongs to the class for whose benefit the statute was enacted;
(2) whether the legislature indicated an intent to create or deny a remedy; and
(3) whether implying a remedy would be consistent with the underlying purposes of the legislative enactment.

Flour Exch. Bldg. Corp. v. State, 524 N.W.2d 496, 499 (Minn.App. 1994), review denied (Minn. Feb. 14, 1995).

Minnesota Statutes section 144.651 evinces the legislature’s intent “to promote the interests and well being of the patients and residents of health care facilities.” Id., subd. 1. The section includes a right to “appropriate medical and personal care” and an “internal grievance procedure” for patients alleging violations of their rights. Id., subds. 6, 20. Appellant’s status as a civilly committed patient at an inpatient facility for an indeterminate period of time demonstrates that he belongs to the class of people for whose benefit the statute was established, satisfying the first factor. See Minn. Stat. § 144.651, subd. 2 (defining “patient” as “a person who is admitted to an acute care inpatient facility for a continuous period longer than 24 hours, for the purpose of diagnosis or treatment bearing on the physical or- mental health of that person”).

But appellant’s argument for a private right of action fails on the remaining factors. The second factor “seeks an indication that the legislature intended to create or deny a remedy for violation of statutory provisions." Flour Exch. Bldg. Corp., 524 N.W.2d at 499. Here, there is no indication, based upon a review of the plain statutory language of section 144.651, that the legislature intended to create a private cause of action for civilly committed patients at an inpatient facility.

With regard to the third' factor, implying a remedy would be inconsistent with the statute’s underlying purpose. Courts are reluctant to imply a private cause of action where a statute has explicitly provided for an alternative remedy. See Becker, 737 N.W.2d at 207 (“[I]t is an elemental canon of statutory construction that where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it.” (citation omitted)). The Minnesota Patients’ Bill of Rights provides a particular remedy. Section 144.651 articulates a grievance procedure for alleged violations of the statute and provides that inpatient facilities

shall have a written internal grievance procedure that, at a minimum, sets forth the process to be followed; specifies time limits, including time limits for facility-response; provides for the patient or .resident to have the assistance of an advocate; requires a written response to ■written grievances; and provides for, a timely decision by an impartial decision maker if the grievance is not otherwise resolved.

Id., subd. 20.

Moreover, exclusive authority to enforce the Minnesota Patients’ Bill of Rights rests with the .commissioner of health. See Minn.' Stat. § 144.653, subd. 1 (2016) (identifying commissioner of health, as the “exclusive state agency charged with the responsibility and duty of inspecting all facilities required .to. be licensed”, under chapter 144); see also State ex rel. Hatch v. Am. Family Mut. Ins. Co., 609 N.W.2d 1, 4 (Minn.App.

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Bluebook (online)
902 N.W.2d 92, 2017 WL 4228715, Counsel Stack Legal Research, https://law.counselstack.com/opinion/favors-v-kneisel-minnctapp-2017.