McDeid v. Johnson
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The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the district court dismissing this complaint brought by patients (collectively, Patients) in the Minnesota Sex Offender Program (MSOP), holding that the district court erred.
Patients were ordered by the Minnesota Commitment Appeals Panel (CAP) to be transferred to Community Preparation Services (CPS), which would have been a reduction in custody. CAP issued Patients' transfers orders, but the orders did not provide a specific date by which the transfers to CPS should occur. State officials did not transfer Patients, and about two years after the transfer orders were issued Patients filed petitions for a writ of mandamus demanding that the transfers be effectuated. The state officials filed motions to dismiss, arguing that qualified immunity shielded them from liability. The district court granted the motions to dismiss, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the state officials had a clear obligation to execute the CAP transfer orders within a reasonable period of time; and (2) remand was required.
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