State v. Hoyt
Minnesota Supreme Court
304 N.W.2d 884 (1981)

- Written by Rich Walter, JD
Facts
Jane Douglass Hoyt (defendant) had a long-standing daily practice of visiting a hospitalized friend named Sharon Seibert. In the course of these visits, Hoyt worked with Seibert in ways that Hoyt deemed therapeutic and beneficial for Seibert’s recovery. Hospital staff, physicians, and Seibert’s legal guardians were all aware of Hoyt’s daily visits but neither expressly approved nor disapproved of Hoyt’s visits or Hoyt’s work with Seibert. However, 22 months after Hoyt’s visits began, and in apparent reaction against Hoyt’s frequently voiced criticism of the care Seibert received from hospital staff, a hospital administrator wrote to inform Hoyt that Hoyt’s visits must cease in order to maintain the hospital’s tranquil environment and staff morale. Hoyt ignored the letter and continued her visits until, at the administrator’s request, police forcibly removed Hoyt from the hospital’s premises and charged Hoyt for trespass. The trial court disallowed almost all the evidence Hoyt proffered in support of her argument that she had a bona fide claim of right to be on hospital premises. The trial court found Hoyt guilty and was affirmed by an intermediate court on appeal. Hoyt appealed to the Minnesota Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Amdahl, J.)
Dissent (Scott, J.)
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