Moonbeams and Radar Waves Justify Commitment, MN Appeals Court Holds

Minnesota case law summary by Attorney Richard Clem: civil commitment.

In the Matter of the Civil Commitment of: Daniel John Stepaniak. MN civil commitment

On October 24, 2013, paramedics brought Daniel Stepaniak to Regions Hospital in St. Paul, MN. There, Stepaniak explained to the hospital staff that he had called the police after being assaulted with microwave guns. Furthermore, he reported that people had been turning into moonbeams and that he could feel being hit by them. He hadn't slept in four days. He had been uable to eat because of radar waves. He believed that a neighbor had tried to harm him with moonbeams and microwave guns. Furthermore, he detected a strong energy coming from the hospital ceiling, and asked hospital staff to identify and destroy the source of this energy. He had thought about suicide and ways to commit suicide. Stepaniak's mother stated that he had been isolating himself and rarely came out of his bedroom. He hadn't been eating or sleeping, and had lost about 30 pounds in the last few months.

A court-appointed psychologist diagnosed Stepaniak with schizophrenia and concluded that he was not able to care for himself or make treatment decisions.

The Ramsey County District Court held a commitment hearing and agreed that Stepaniak was mentally ill and met the statutory criteria for civil commitment. Stepaniak, represented by Prior Lake attorney Rick E. Mattox, appealed this determination to the Minnesota Court of Appeals.

The Court of Appeals examined the evidence and concluded that it supported the lower court's findings. For example, Stepaniak argued that "many people need to lose weight," but the Court of Appeals found no evidence that the weight loss was attributable to a health-conscious diet. Instead, it found that the weight loss was a result of the psychotic symptoms, delusional beliefs, and paranoia. The danger had become apparent, and the Court of Appeals held that it justified the commitment.

The court's unpublished decision was authored by Judge Larkin, and concurred by Judges Worke and Kirk.

No. A13-2168 (Minn. Ct. App. Mar. 31, 2014).

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


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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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