In the Matter of the Civil Commitment of: Mustaf Nur Jama.

This opinion is nonprecedential except as provided by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
A25-0073

In the Matter of the Civil Commitment of: Mustaf Nur Jama.

Filed June 30, 2025
Affirmed
Larson, Judge

Hennepin County District Court
File No. 27-MH-PR-24-1322

Gabe Monson, Hennepin County Adult Representation Services, Minneapolis, Minnesota
(for appellant Mustaf Nur Jama)

Mary F. Moriarty, Hennepin County Attorney, Annsara Lovejoy Elasky, Assistant County
Attorney, Minneapolis, Minnesota (for respondent Abbott Northwestern Hospital)

Considered and decided by Larson, Presiding Judge; Bentley, Judge; and Kirk,
Judge.∗
NONPRECEDENTIAL OPINION
LARSON, Judge
Appellant Mustaf Nur Jama appeals a district court order civilly committing him as
a person who poses a risk of harm due to a mental illness. Jama argues the district court
erred when it determined that he had recently attempted or threatened to physically harm
himself or others. See Minn. Stat. § 253B.02, subd. 17a(a)(3) (2024). We affirm.

∗ Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
2
FACTS
In December 2024, Hennepin County Community Outreach for Psychiatric
Emergencies assessed Jama, determined that he was experiencing psychosis, and
transported him to respondent Abbott Northwestern Hospital (Abbott) where he was placed
on an emergency hold.
Jama petitioned the district court for release from the emergency hold. Abbott
petitioned the district court to civilly commit Jama and authorize neuroleptic medications.
The district court denied Jama’s petition. The district court scheduled a psychiatric
evaluation and preliminary hearing and directed that the emergency hold continue during
these proceedings. After the preliminary hearing, the district court scheduled a
commitment hearing. At the commitment hearing, the district court heard testimony from
Jama and his psychiatrist. The district court also took judicial notice of Jama’s psychiatric
evaluation. The psychiatric evaluation diagnosed Jama with a mental illness, opined that
Jama met the criteria for commitment, and recommended neuroleptic medications.
The district court thereafter filed an order civilly committing Jama as a person who
poses a risk of harm due to mental illness, concluding that Jama posed a substantial
likelihood of harm to himself or others. The district court also filed an order authorizing
neuroleptic medications.
Jama appeals.
3
DECISION
Jama appeals the district court’s order for commitment. 1 Specifically, Jama
challenges the district court’s determination that he recently attempted or threatened to
physically harm himself or others.2
A district court may civilly commit an individual if it “finds by clear and convincing
evidence that the proposed patient is a person who poses a risk of harm due to mental
illness” and “that there is no suitable alternative to judicial commitment.” Minn. Stat.
§ 253B.09, subd. 1(a) (2024). A person “poses a risk of harm due to mental illness” if they
have “an organic disorder of the brain or a substantial psychiatric disorder of thought,
mood, perception, orientation, or memory ”
3 and, as a result of their condition, “poses a
substantial likelihood of physical harm to self or others.” Minn. Stat. § 253B.02,
subd. 17a(a) (2024). A “substantial likelihood of physical harm to self or others” may be

1 Jama also appealed the order authorizing neuroleptic medications but does not raise any
argument challenging that order in his brief. Inadequately briefed issues are not properly
before this court. Melina v. Chaplin, 327 N.W.2d 19, 20 (Minn. 1982).
2 Jama also challenges the district court’s conclusion that he failed “ to obtain necessary
food, clothing, shelter, or medical care as a result of [his] impairment.” See Minn. Stat.
§ 253B.02, subd. 17a(a)(1) (2024). Because we may affirm the district court’s commitment
order solely on the basis that Jama recently attempted or threatened to physically harm
himself or others, we decline to reach this issue. See id., subd. 17a(a)(1)-(4) (2024) (listing
four circumstances demonstrating that a person “poses a substantial likelihood of physical
harm to self or others” and using the word “or”); State v. Loge , 608 N.W.2d 152, 155
(Minn. 2000) (“[I]n the absence of some ambiguity surrounding the legislature’s use of the
word ‘or,’ we will read it in the disjunctive and require that only one of the possible factual
situations be present in order for the statute to be satisfied.”).
3 Jama admits that he “ha[s] a mental illness” and does not challenge that required element
on appeal.
4
“demonstrated by,” as relevant here, “a recent attempt or threat to physically harm self or
others.” Id., subd. 17a(a)(3).
When reviewing a civil-commitment order, we examine whether the district court
complied with the commitment statute and whether the district court’s factual findings
support its legal conclusions. In re Knops, 536 N.W.2d 616, 620 (Minn. 1995). We do not
set aside factual findings unless they are clearly erroneous. Id. “[F]indings are clearly
erroneous when they are manifestly contrary to the weight of the evidence or not
reasonably supported by the evidence as a whole.” In re Civ. Commitment of Kenney, 963
N.W.2d 214, 221 (Minn. 2021) (quotation omitted). When reviewing for clear error, we
(1) view the evidence in the light most favorable to the findings; (2) do not find our own
facts; (3) do not reweigh the evidence; and (4) do not “reconcile conflicting evidence.” Id.
at 221-22 (quotation omitted). Thus, we
need not go into an extended discussion of the evidence to
prove or demonstrate the correctness of the findings of the
[district] court. Rather, because the factfinder has the primary
responsibility of determining the fact issues and the advantage
of observing the witnesses in view of all the circumstances
surrounding the entire proceeding, [our] duty is fully
performed after [we have] fairly considered all the evidence
and [have] determined that the evidence reasonably supports
the decision.

Id. at 222 (quotations and citation omitted). “We review de novo whether there is clear
and convincing evidence in the record to support the district court’s conclusion that an
[individual] meets the standards for commitment.” In re Thulin, 660 N.W.2d 140, 144
(Minn. App. 2003).
5
Jama asserts that the district court erred when it determined that he had recently
attempted or threatened to physically harm himself or others. He argues that its findings
to support this conclusion are based solely on unreliable hearsay evidence. At a
commitment hearing, the district court “may admit all relevant, reliable evidence, including
but not limited to the respondent’s medical records, without requiring foundation
witnesses.” Minn. Spec. R. Commit. & Treat. Act 15. The district court also “shall admit
all relevant evidence” and “make its determination upon the entire record pursuant to the
Rules of Evidence.” Minn. Stat. § 253B.08, subd. 7 (2024). We have interpreted these
provisions to allow the district court to admit relevant, reliable hearsay evidence in
commitment proceedings. See In re Civ. Commitment of Williams, 735 N.W.2d 727, 730-
32 (Minn. App. 2007), rev. denied (Minn. Sept. 26, 2007). Hearsay is an out-of -court
statement offered “to prove the truth of the matter asserted. ” See Minn. R. Evid. 801(c).
Indicia that a hearsay statement is reliable include temporal proximity between the hearsay
statement and the event, and whether the statement is a first-hand account. See Williams,
735 N.W.2d. at 732.
In support of his argument, Jama likens this case to our nonprecedential decision In
re Civil Commitment of Jackman. No. A18-0890, 2018 WL 6273116 (Minn. App. Dec. 3,
2018).
4 There, the district court received exhibits offered by the county over the appellant’s
hearsay objection at a commitment hearing. Id. at *1. The exhibits contained information
that an unknown source relayed to the appellant’s sister-in-law, who relayed the

4 This case is nonprecedential and, therefore, not binding. We cite nonprecedential cases
as persuasive authority only. See Minn. R. Civ. App. P. 136.01, subd. 1(c).
6
information to the Dakota County Crisis Unit, who relayed the information to the Hennepin
County Medical Center. Id. The district court did not make any reliability findings as to
the hearsay in the exhibits. Id. at *2. On appeal, the appellant argued the district court
erred when it admitted the hearsay. Id. We agreed that “the hearsay statements present[ed]
significant reliability questions” given that “they came from an unknown source and were
then relayed through several people.” Id. We also noted that the appellant’s sister-in-law
did not testify to add context to the hearsay statements and that the appellant’s testimony
suggested the hearsay statements exaggerated his conduct. Id. After removing the findings
that solely relied on the hearsay statements, we determined that the remaining findings
were insufficient to support the appellant’s commitment and, accordingly, reversed and
remanded for reliability findings. Id. at *3-4.
We conclude this case is distinguishable from Jackman. Unlike Jackman, the
district court did not rely solely on the challenged hearsay statements to conclude that Jama
recently threatened to physically harm others.
5 Instead, the record shows the district court
also relied on Jama’s sister’s report that she observed Jama exhibiting threatening
behaviors toward their brothers. The psychiatrist who performed Jama’s psychiatric
evaluation relied on these behaviors in making her recommendation. And the district court
found the recommendation to be persuasive, specifically noting that “[Jama’s] family

5 We note that Jama’s confidential medical records are relevant here, as they contain the
hearsay statements that Jama challenges. See Minn. R. Pub. Access to Recs. of Jud.
Branch 4, subd. 1(f) (providing that medical records in civil commitment proceeding are
not publicly accessible). While we need not disclose the confidential information
contained in Jama’s medical records, we have fully reviewed and considered those
documents.
7
reported that [Jama] has been exhibiting threatening behaviors toward his family
members.”
Jama does not challenge the district court’s finding as to the threatening behavior s
he exhibited toward his brothers. And we are satisfied that the record supports this finding.
See Wilson v. Moline, 47 N.W.2d 865, 870 (Minn. 1951) (stating that function of “an
appellate court does not require [it] to discuss and review in detail the evidence for the
purpose of determining that it supports the [district] court’s findings,” and that an appellate
court performs its duty when it “consider[s] all the evidence . . . and determine[s] that it
reasonably supports the findings”); Cook v. Arimitsu, 907 N.W.2d 233, 240 n.3 (Minn.
App. 2018) (applying this aspect of Wilson), rev. denied (Minn. Apr. 17, 2018). Moreover,
unlike the third-hand accounts in Jackman, Jama’s sister observed these threatening
behaviors first-hand. Thus, even if we remove the findings that Jama challenges, there is
still evidence to sustain the district court’s finding that Jama recently threatened physical
harm to others.
Accordingly, we affirm the district court’s order for commitment.
Affirmed.