Case: Kennedy v. Carlson

NA | Minnesota state trial court

Filed Date: 1992

Closed Date: 1996

Clearinghouse coding complete

Case Summary

In April 1992, Plaintiff, the chief public defender for the Fourth Judicial District instituted a declaratory judgment action in the Hennepin County District Court pursuant to state law. Plaintiff alleged that the Minnesota statute establishing the funding system for the public defender's office does not provide sufficient funds for its operation. Plaintiff further alleged that the lack of funding violated indigent defendants constitutionally rights to effective counsel because of an arbitrar…

In April 1992, Plaintiff, the chief public defender for the Fourth Judicial District instituted a declaratory judgment action in the Hennepin County District Court pursuant to state law. Plaintiff alleged that the Minnesota statute establishing the funding system for the public defender's office does not provide sufficient funds for its operation. Plaintiff further alleged that the lack of funding violated indigent defendants constitutionally rights to effective counsel because of an arbitrary cap on state spending for public defender services. The District Court (Lindstrom, J.) found the statute unconstitutional. The defendants appealed to the Minnesota Supreme Court.

On February 16, 1996 the Minnesota Supreme Court (Keith, C.J.) reversed the District Court's judgment. It found that the constitutional violations of ineffective assistance of counsel were too speculative since there was no evidence that any public defender was unable to effectively assist a client.

Summary Authors

Dayna Frenkel (2/25/2009)

People


Judge(s)

Keith, A. M. (Minnesota)

Attorney for Plaintiff

Kennedy, William R. (Minnesota)

Murrin, David (Minnesota)

Attorney for Defendant

Humphrey, Hubert H. III (Minnesota)

Tiegel, Lisa (Minnesota)

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Documents in the Clearinghouse

Document

No. C0-95-1282 (SCt)

Opinion

Minnesota state supreme court

Feb. 16, 1996

Feb. 16, 1996

Order/Opinion

544 N.W.2d 544

Resources

Docket

Last updated Feb. 5, 2024, 3:15 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Minnesota

Case Type(s):

Indigent Defense

Key Dates

Filing Date: 1992

Closing Date: 1996

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Plaintiff is the chief public defender seeking a declaratory relief from a Minnesota statute that plaintiff says doesn't provide sufficient funds to the Public Defender's Office to allow it to provide effective counsel to indigent defendants.

Plaintiff Type(s):

State Plaintiff

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Commissioner of Hennepin County, State

Governor Arne Carlson, State

Treasurer Michael McGrath, State

Case Details

Causes of Action:

State law

Available Documents:

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

Litigation

Issues

General:

Funding