MN Civil Commitment

Minnesota case law summary by Attorney Richard Clem: MN Civil Commitment.

In the Matter of the Civil Commitment of: Gary George Spicer. MN Civil Commitment

Gary George Spicer was civilly committed as a sexually dangerous person (SDP) and a sexual psychopathic personality (SPP). This was based on convictions dating back to 2005, as well as incidents that didn't result in prosecution.

On appeal, the Minnesota Court of Appeals held that the district court's findings of fact lacked particularity and did not adequately demonstrate the district court's consideration of the factors relevant to determining whether appellant satisfies the criteria for commitment as an SDP or an SPP. For that reason, the appeals court remanded the case to Sherburne County District Court.

No. A13-2120 (Minn. Ct. App. Aug. 18, 2014).

Please see the original opinion for the court's exact language.


Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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