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Fourth Circuit Upholds Federal Civil Commitment Statute Against Constitutional Challenge
The procedures for civil commitment of “sexually dangerous” federal offenders do not violate due process, the U.S. Court of Appeals for the Fourth Circuit held on December 6, 2010.
In 2006, the United States initiated civil commitment proceedings against Graydon Earl Comstock as he was nearing the end of his federal prison sentence for sexually exploiting minors via the Internet.
Under the terms of the Adam Walsh Act, Comstock’s release was automatically stayed until the government’s petition for commitment could be decided.
Rather than reach the merits of the commitment petition, though, the district court declared the federal civil commitment statute unconstitutional. The court held that Congress had exceeded its authority in enacting the statute, and even assuming the statute was a proper exercise of Congress’ authority, the procedures for civil commitment under the law violated due process.
In January 2009, a panel of the Fourth Circuit affirmed the district court’s conclusion that the civil commitment process exceeded Congress’ authority. The Court of Appeals did not address the district court’s alternate finding that the commitment procedures violated due process.
On May 17, 2010, however, the U.S. Supreme Court reversed the Fourth Circuit. The Supreme Court held the civil commitment law was a proper exercise of Congress’ authority under the Necessary and Proper Clause. The Court did not reach the merits of the due process challenge, and remanded the case to the appellate court. [See: PLN, Dec. 2010, p.44].
On remand, the Fourth Circuit rejected the district court’s conclusion that the procedures for civil commitment violated due process.
The district court had accepted Comstock’s argument that the statute impermissibly allowed civil commitment upon a showing of “sexual dangerousness” by “clear and convincing evidence.” According to the court, sexual dangerousness was required to be shown “beyond a reasonable doubt.”
The Fourth Circuit concluded, however, that the reasonable doubt standard had no applicability in the civil commitment process. “The Supreme Court has not once held that the criminal standard of proof applies in any civil commitment proceeding – or indeed any kind of civil proceeding – other than juvenile delinquency hearing,” the appellate court wrote.
Accordingly, the judgment of the district court was reversed and the case remanded for further proceedings. See: United States v. Comstock, 627 F.3d 513 (4th Cir. 2010).
In 2006, the United States initiated civil commitment proceedings against Graydon Earl Comstock as he was nearing the end of his federal prison sentence for sexually exploiting minors via the Internet.
Under the terms of the Adam Walsh Act, Comstock’s release was automatically stayed until the government’s petition for commitment could be decided.
Rather than reach the merits of the commitment petition, though, the district court declared the federal civil commitment statute unconstitutional. The court held that Congress had exceeded its authority in enacting the statute, and even assuming the statute was a proper exercise of Congress’ authority, the procedures for civil commitment under the law violated due process.
In January 2009, a panel of the Fourth Circuit affirmed the district court’s conclusion that the civil commitment process exceeded Congress’ authority. The Court of Appeals did not address the district court’s alternate finding that the commitment procedures violated due process.
On May 17, 2010, however, the U.S. Supreme Court reversed the Fourth Circuit. The Supreme Court held the civil commitment law was a proper exercise of Congress’ authority under the Necessary and Proper Clause. The Court did not reach the merits of the due process challenge, and remanded the case to the appellate court. [See: PLN, Dec. 2010, p.44].
On remand, the Fourth Circuit rejected the district court’s conclusion that the procedures for civil commitment violated due process.
The district court had accepted Comstock’s argument that the statute impermissibly allowed civil commitment upon a showing of “sexual dangerousness” by “clear and convincing evidence.” According to the court, sexual dangerousness was required to be shown “beyond a reasonable doubt.”
The Fourth Circuit concluded, however, that the reasonable doubt standard had no applicability in the civil commitment process. “The Supreme Court has not once held that the criminal standard of proof applies in any civil commitment proceeding – or indeed any kind of civil proceeding – other than juvenile delinquency hearing,” the appellate court wrote.
Accordingly, the judgment of the district court was reversed and the case remanded for further proceedings. See: United States v. Comstock, 627 F.3d 513 (4th Cir. 2010).
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Related legal case
United States v. Comstock
| Year | 2010 |
|---|---|
| Cite | 627 F.3d 513 (4th Cir. 2010) |
| Level | Court of Appeals |
| Injunction Status | N/A |