Cited by

See Beaulieu v. Minnesota Dep ’t of Human Servs., (noting appellant’s concession that Sixth Amendment does not apply in civil- commitment proceeding), aff’d, Favors v. Jesson, No. A13- 1579, 2014 WL 997055, at *4 (Minn. App. Mar.

Servs., -51 (Minn. App. 2011), aff’d

Servs., -49 (Minn. App. 2011), aff’d

see also Beaulieu v. Minn. Dep’t of Human Servs., -24 (Minn. 2013) (recognizing that claims of res judicata and collateral estoppel may be forfeited if not adequately raised in district court); (declining to consider whether res judicata applied and explaining that, “because

Servs., (noting that Strickland analysis applies in a civil-commitment context), aff’d on other grounds, (applying Strickland in a juvenile-delinquency context).

Servs., (recognizing multiple other provisions of the Sixth Amendment, including right to effective assistance of counsel, have applied to only criminal defendants, 3 not civilly committed persons), aff’d

Servs., d 542, 550 (Minn. App. 2011) (stating that Strickland applies in civil-commitment context), aff’d on other grounds , ).

See Beaulieu v. Minn. Dep’t of Human Servs., (stating that “[t]he doctrines of res judicata and collateral estoppel .

Servs., aff’d on other grounds

Servs., (noting that Strickland analysis is applicable in civil- commitment context), aff’d on other grounds

(applying Thiele in a commitment appeal).

(applying Strickland in the civil commitment context), aff’d on other grounds

d 542, 546 (Minn. App. 2011), aff’d, ).

Bassett v. Tahash , (emphasis added); see also 19 Beaulieu v. Minn. Dep’t of Human Servs., (stating that a petitioner “may obtain habeas relief only if he can establish that he is restrained because of a constitutional violation” ), aff’d on other grounds

mmitted under color of state law.” First, “neither the United States Supreme Court nor the Minnesota Supreme Court has held that the Due Process Clause of the Fourteenth Amendment confers a right to the effective assistance of counsel on a person who is the subject of a civil -commitment proceeding.” Beaulieu v. Minn. Dep’t of Human Servs., -550 (Minn. App. 2011), aff’d, see also In re Civil Commitment of Johnson, __N.W.2d__, 2019 WL 2495668, at *3 (Minn. App. July 17, 2019).

In re Civil Commitment of Johnson, __N.W.2d__, 2019 WL 2495668, *3 (Minn. App. June 17, 2019) (citing Beaulieu v. Minn. Dep’t of Human Servs., aff’d on other grounds, (holding that person subject to civil- commitment proceeding does not have constitutional right to counsel)) .

(citing Beaulieu v. Minn. Dep’t of Human Servs., aff’d on other grounds, ).

543 (Minn. App. 2011), aff'd on other grounds

(concluding issue waived where appellant failed to raise the issue before the lower court).

Beaulieu v. Minn. Dep’t Human Servs.

Dep’t of Human Servs., (statutory), aff’d on other grounds, .

See, e.g., Beaulieu v. Minn. Dep’t of Human Servs., d 542, 550 (Minn. App. 2011), aff’d, .

Beaulieu v. Minnesota Dep’t of Human Servs., (); d 666, 671 (Minn. App. 2004), review denied (Minn. Dec.

A prisoner may use a habeas petition to obtain relief from custody that is in “violation of a constitutional right.” Beaulieu v. Minnesota Dep’t of Human Servs., aff’d on other grounds

–48 (Minn. App. 2011), aff’d on other grounds, see also State v. Clark, 270 Minn. 181, 183, (no ting that “numerous decisions of both th[e Minnesota Supreme] [C]ourt and the Supreme Court of the United States” indicate that “habeas corpus may be used as a postconvicti on procedure to inquire into a lleged violations of

Beaulieu v. Minn. Dep’t of Human Servs., d 542, 546-48 (Minn. App. 2011), aff’d on other grounds

To obtain habeas relief, a petitioner “must allege either a lack of jurisdiction or a violation of a constitutional right.” Beaulieu v. Minn. Dep’t of Human Servs., aff’d

Beaulieu v. Minn. Dep’t of Human Servs., (quotation omitted).

Beaulieu v. Minnesota Dep’t of Human Servs., aff’d

See, (applying Strickland in juvenile-delinquency context); see also Beaulieu v. Minn. Dep’t of Human Servs., (applying Strickland in civil-commitment context), aff’d

Beaulieu v. Minn. Dep’t 4 of Human Servs., -48 (Minn. App. 2011), aff’d on other grounds

See Beaulieu v. Minn. Dep’t of Human Servs., -24 (Minn. 2013) (holding that a collateral estoppel argument was not waived when the argument was sufficiently presented to the district court).

es judicata precludes “a subsequent claim when: (1) the earlier claim involved the same claim for relief; (2) the earlier claim involved the same parties or their privies; (3) there was a final judgment on the merits; and (4) the estopped party had a full and fair opportunity to litigate the matter.” Beaulieu v. Minn. Dep’t of Human Servs., ().

Beaulieu v. Minn. Dep’t of Human Servs., (rejecting argument without reaching its merits because MSOP patient failed to adequately raise the issue in the district court).

., −48 (Minn. App. 2011) (stating that “the supreme court regards habeas as a remedy only for a jurisdictional 4 defect or a constitutional violation” and that “[t]he supreme court has refrained from expanding the scope of the writ of habeas corpus to encompass statutory violations that give rise to unlawful restraint”), aff’d

See Beaulieu v. Minn. Dep’t. of Human Servs., aff’d on other grounds