Johnson v. Minnesota

Facts

Stewart, a parolee on supervised release status, murdered Melissa Noelle Johnson. Stewart was released from Minnesota's maximum-security prison in St. Cloud and told to report to 180 Degrees, a halfway house located in Minneapolis, Minnesota. Stewart's parole agreement stated that he was to report directly to 180 Degrees and to telephone his supervising agent within 24 hours of his release. Stewart did neither; instead, he engaged in an eight-day crime spree. Stewart abducted Johnson at gunpoint and drove her to the outskirts of the city, where he raped her. Stewart then stabbed Johnson to death. Stewart surrendered to the police three days later. He confessed to the abduction, rape, and murder of Johnson, and, after a trial, was sentenced to life imprisonment without parole. Stewart's record reveals two prior convictions for criminal sexual conduct, both of which crimes were committed while he was on parole. After completing two-thirds of his sentence for the second conviction for criminal sexual conduct, Stewart was released from prison on July 4, 1991, on the condition that he reside at a halfway house. The release conforms with the criminal justice policy of the state. When a prisoner has served at least two-thirds of a sentence and has earned 'good time,' the Executive Officer of Adult Release may authorize the prisoner's release from prison and referral to a supervised release program, such as a halfway house. The prisoner serves the balance of the sentence in accordance with a release plan. If upon release, the prisoner fails to report to the halfway house or fails to contact his supervising agent, a presumption arises in favor of reincarceration. Stewart failed to report as required, but a fugitive warrant was not issued until Monday, July 8. Thomas Lamb, Stewart's supervising agent, was on vacation on Thursday, July 4, the day Stewart was released. Lamb was also on vacation on Friday, July 5, the day Stewart was to report to 180 Degrees. The county did have an officer on duty that day to assume the responsibilities of any supervising agents who were on vacation. When Lamb returned to work on Monday, he telephoned 180 Degrees and learned that Stewart had failed to report. Stewart was arrested on Friday, July 12, four days after the issuance of the warrant. Ps, trustees for the heirs and next-of-kin of Johnson (trustees), commenced a wrongful death action against Ds The trustees alleged that appellants had a duty to control Stewart while he was a parolee on supervised release status and that their negligence caused Johnson's death. The district court dismissed the trustees' wrongful death action on the grounds that the trustees' claims against the state, the county, and their agents are barred by statutory immunity and official immunity. The court also granted 180 Degrees' motion to dismiss on the grounds that 180 Degrees did not owe a duty to control Stewart or to warn Johnson. On appeal, the court held that the failure to determine Stewart's whereabouts after his release and the failure to obtain a warrant were ministerial failures unprotected by statutory immunity or official immunity. It held that there was a duty to control Stewart and determine his whereabouts, as well as a duty to immediately issue a warrant upon Stewart's violation of his supervised release plan. It concluded that it was foreseeable that Stewart would attempt to escape and engage in criminal sexual conduct. Ds appealed. Ds argue that there was no duty to control Stewart and that Johnson's death was not foreseeable as a matter of law.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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