In the Matter of the Civil Commitment of: Stephen Lyle Love

Opinion

This opinion is nonprecedential except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA

IN COURT OF APPEALS

A26-0568

In the Matter of the Civil Commitment of: Stephen Lyle Love.

Filed August 31, 2026

Affirmed

Reyes, Judge

Rice County District Court File No. 66-P8-98-000331

Stephen Lyle Love, Moose Lake, Minnesota (self-represented appellant)

Keith Ellison, Attorney General, Angela Helseth Kiese, Assistant Attorney General, St. Paul, Minnesota; and

Brian Mortenson, Rice County Attorney, Faribault, Minnesota (for respondent State of Minnesota)

Considered and decided by Connolly, Presiding Judge; Reyes, Judge; and Rasmusson, Judge.

NONPRECEDENTIAL OPINION

REYES, Judge Appellant challenges the district court’s denial of his motion under Minnesota Rule of Civil Procedure 60.02 for relief from his indeterminate civil commitment, arguing that he had a right to represent himself in his initial civil-commitment proceedings and that the district court violated that right. We affirm.

FACTS

In 1999, a district court filed an order granting respondent State of Minnesota’s petition for the indeterminate civil commitment of appellant Stephen Lyle Love as a sexually dangerous person (SDP) and a sexual psychopathic personality (SPP). Court- appointed counsel represented appellant throughout the proceedings and on appeal. See In re Love, No. C4-98-2076, 1999 WL 243602, at *1-3 (Minn. App. Apr. 27, 1999) (affirming indeterminate commitment as SDP and SPP).

In September 2025, appellant filed a motion under Minnesota Rule of Civil Procedure 60.02(d), (e), and (f), seeking relief from the 1999 civil-commitment order. Appellant argued that “when the [district court] erroneously appointed counsel” for him at the commencement of the commitment proceedings his “right to be afford[ed] the opportunity to waive counsel was denied, resulting in structural error, requiring automatic reversal.” Appellant’s argument relied on In re Civil Commitment of Benson, in which the supreme court held that a civilly committed person is not precluded from representing themself in proceedings before the Commitment Appeal Panel (CAP). See 12 N.W.3d 711, 721 (Minn. 2024) (citing Minn. Stat. § 253D.20 (2022)); see also id. at 721 n.13 (declining to decide “whether there is a constitutional right to self-representation in civil commitment proceedings”).

In February 2026, the district court filed an order denying appellant’s motion. It explained that (1) the structural-error doctrine did not apply; (2) the district court had jurisdiction when it filed the 1999 commitment order, making relief under rule 60.02(d) unwarranted; (3) there has been no change in relevant law that would warrant relief under

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rule 60.02(e); and (4) by bringing “the same exact claim” for relief under both clause (e) and (f), appellant did not show the “exceptional circumstances” required for relief under rule 60.02(f). The district court found “no evidence that [appellant] ever requested to waive his right to counsel or represent himself during his civil commitment proceedings,” meaning that, “[i]n essence, [appellant] argues that the district court abused its discretion by not granting a request he never made.”

This appeal follows.

DECISION

I. The district court did not abuse its discretion by denying appellant’s rule 60.02 motion.

Appellant argues that the district court abused its discretion by denying his motion under Minnesota Rule of Civil Procedure 60.02(d), (e), and (f). We disagree.

“This court reviews a district court’s denial of a rule 60.02 motion 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). “A district court abuses its discretion by making findings of fact that are unsupported by the evidence, misapplying the law, or delivering a decision that is against logic and the facts on record.” Woolsey v. Woolsey, 975 N.W.2d 502, 506 (Minn. 2022) (quotation omitted).

Rule 60.02 provides that a district court may, in certain circumstances, relieve a party from final judgments, orders, or proceedings. “The burden of proof in a proceeding under Rule 60.02 is on the party seeking relief.” City of Barnum v. Sabri, 657 N.W.2d 201, 205 (Minn. App. 2003).

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Clause (d) of rule 60.02 allows a district court to grant relief to parties if a judgment is void. A judgment or order “is void if the issuing court lacked jurisdiction over the subject matter, lacked personal jurisdiction over the parties through a failure of service that has not been waived, or acted in a manner inconsistent with due process.” Bode v. Minn. Dep’t of Nat. Res., 594 N.W.2d 257, 261 (Minn. App. 1999), aff’d, 612 N.W.2d 862 (Minn. 2000). Appellant provides no legally supported argument that the order civilly committing him is void for any of these reasons. We therefore decline to consider appellant’s challenge to the district court’s determination that appellant is not entitled to relief under clause (d). See Fannie Mae v. Heather Apartments Ltd. P’ship, 811 N.W.2d 596, 600 n.2 (Minn. 2012) (“Summary arguments made without citation to legal support are waived.”); Custom Farm Servs., Inc. v. Collins, 238 N.W.2d 608, 609 (Minn. 1976) (stating that appellate courts do not presume error).

Clause (e) of rule 60.02 allows a district court to grant relief to parties if it determines that changed circumstances exist that “render it inequitable for the judgment to have prospective application.” Sabri, 657 N.W.2d at 207. “The changed circumstances . . . must pertain to either the applicable law or the relevant facts.” In re Civ. Commitment of Moen, 837 N.W.2d 40, 48 (Minn. App. 2013), rev. denied (Minn. Oct. 15, 2013). Appellant argues that Benson constitutes a change in appliable law. Benson interpreted the statute providing a right to counsel to a person who has already been civilly committed and who is a party to chapter 253D proceedings. 12 N.W.3d at 720-21; Minn. Stat. § 253D.20 (“A committed person has the right to be represented by counsel at any proceeding under this chapter.”). Benson explained that a person provided a right to counsel by that statute

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may request the permission of the CAP to represent themselves and waive their statutory right to counsel. See 12 N.W.3d at 720; see also id. at 721 n.13 (concluding that “section 253D.20 allows for self-representation” but declining to decide “whether there is a constitutional right to self-representation in civil commitment proceedings”). Benson does not constitute a change in applicable law because appellant’s right to counsel in his initial civil-commitment proceedings arose from a different statute, which applies only to initial commitment proceedings under chapter 253B. See Minn. Stat. § 253B.07, subd. 2c (1998). Appellant’s argument under clause (e) of rule 60.02 fails.

Clause (f) of rule 60.02 allows a district court to grant relief for “[a]ny other reason justifying relief from the operation of the judgment.” Appellant does not provide a distinct argument for relief under rule 60.02(f). Instead, he appears to rely on the same arguments for relief under clauses (d), (e), and (f). But clause (f) of rule 60.02 operates as “a residual clause, designed to afford relief only under exceptional circumstances not addressed by clauses (a) through (e).” Johnson, 931 N.W.2d at 655 (emphasis added) (quotation omitted). The district court determined that appellant “cannot get relief under [clause (f)] for a contention that specifically invokes relief under [clause (e)].” Appellant provides no legally supported argument regarding this determination. We therefore decline to consider appellant’s challenge to the district court’s determination that appellant is not entitled to relief under clause (f). See Fannie Mae, 811 N.W.2d at 600 n.2; Custom Farm Servs., 238 N.W.2d at 609.

Lastly, appellant challenges the district court’s determination that the structural-

error doctrine does not apply to the claims in his rule 60.02 motion. “Structural error is a

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very limited class of error, which generally requires automatic reversal” of a criminal defendant’s conviction. State v. Bey, 975 N.W.2d 511, 520 (Minn. 2022). Appellant does not provide legal argument or authority in support of the proposition that the structural- error doctrine applies to civil-commitment cases. See Fannie Mae, 811 N.W.2d at 600 n.2. We conclude that the district court did not abuse its discretion by denying appellant’s rule 60.02 motion. II. We decline to consider appellant’s remaining arguments.

We decline to consider appellant’s remaining arguments because appellant either failed to present them to the district court or he failed to support them with relevant legal authority. See Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988) (stating that appellate courts generally do not consider issues not presented to and considered by district court); State v. Taylor, 910 N.W.2d 60, 71 (Minn. App. 2018) (declining to address arguments offered without citation to supporting “evidence in the record or relevant legal authority”), rev. denied (Minn. June 19, 2018).

First, appellant contends that the district court should have “addressed the Finden factors.” See Finden v. Klaas, 128 N.W.2d 748, 750 (Minn. 1964) (providing four-factor test to decide 60.02 requests for relief). Because appellant presented no argument about the Finden factors to the district court, we decline to consider the issue on appeal. See Thiele, 425 N.W.2d at 582.

Second, appellant appears to argue that Faretta v. California recognized a right to self-representation in civil-commitment proceedings. See 422 U.S. 806, 807 (1975) (recognizing a right to self-representation in criminal cases under the Sixth Amendment to

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the United States Constitution). We decline to consider this argument because appellant did not present it to the district court. See In re Welfare of C.L.L., 310 N.W.2d 555, 557 (Minn. 1981) (“The appellant cannot now for the first time raise constitutional issues that were not raised in the [district] court.”).

Third, appellant identifies the Sixth and Fourteenth Amendments to the United States Constitution as supporting a right to self-representation in civil-commitment proceedings. We decline to consider this argument as well because appellant did not present it to the district court. See id.

Fourth, appellant asserts that the district court should have examined whether the state, during his initial commitment proceedings, “had subjective and implied knowledge of [a]ppellant’s constitutional rights, yet stayed silent.” We decline to consider this issue because appellant did not provide an argument supported by relevant legal authority. 1 See Taylor, 910 N.W.2d at 71.

Affirmed.

1 Love cited only one case that addresses a deliberate-indifference claim under the Eighth Amendment. See Jackson v. Lightsey, 775 F.3d 170, 178 (4th Cir. 2014). However, appellant does not make a deliberate-indifference claim under the Eighth Amendment here.