Thursday, February 24, 2005

Court upholds juvenile civil commitment provision

The Court unanimously upheld CA’s juvenile civil commitment provision (see background in yesterday’s post). Although the statute does not expressly require a finding that the person’s mental disorder causes serious difficulty in controlling behavior, the Court held that the statute should be interpreted as containing such a requirement in order to preserve its constitutionality.

The Court refused to define “mental disorder” either expressly or by reference to definitions found in CA’s Sexually Violent Predator Act and analogous civil commitment schemes. When (if) the legislature decides to define “mental disorder,” due process simply requires proof that the disorder causes the person to have “serious difficulty” controlling dangerous behavior.

Since the jury was not instructed on this requirement, the Court remanded. However, despite extensive testimony at trial from psychologists and corrections officers, the Court noted that “there was little evidence [that] defendant’s mental abnormality caused him serious difficulty controlling his dangerous behavior.”

Wednesday, February 23, 2005

Tomorrow's opinion

The Court will issue an opinion tomorrow in In re Howard N., a case involving a constitutional challenge to CA's provision for civil commitment of juvenile sex offenders. (Welfare & Institutions Code section 1800 et seq.). After a jury trial which included testimony from psychologists and correctional officers, the Superior Court extended Howard N.'s confinement by 2 years under the civil commitment statute.

The Fifth District reversed, holding that section 1800 does not meet the constitutional requirements the US Supreme Court has applied to similar civil commitment schemes. See Kansas v. Hendricks, 521 U.S. 346 (1997); Kansas v. Crane, 534 U.S. 407 (2002).

This case marks the 1st time the CA Supreme Court will rule on the constitutionality of section 1800, although the Court has addressed (and upheld) other similar provisions before, including California's Sexually Violent Predators Act. (Ca. Pen. Code section 6600 et seq.).

Oral argument schedule - March 9

Oral arguments scheduled for Wednesday, March 9 at 9 AM:

1. Warrick v. Superior Court
2. People v. Colin Dickey [automatic appeal]

Oral argument schedule - March 8

Oral arguments scheduled for Tuesday, March 8 at 9 AM:

1. Sierra Club v. California Coastal Commission
2. People v. Wright
3. People v. Randle
4. People v. Williams
5. Jevne v. Superior Court

Welcome to the CA S.Ct. blog

Welcome to the California Supreme Court blog. The aim of this blog is to provide readers, specifically law students, with news and information about California's highest court by collecting Court opinions, news articles, commentary, briefs and other documents.