Kansas v. Crane
Encyclopedia
Kansas v. Crane, is a United States Supreme Court case in which the Court upheld the Kansas Sexually Violent Predator Act (SVPA) as consistent with substantive due process
. The Court clarified that its earlier holding in Kansas v. Hendricks
did not set forth a requirement of total or complete lack of control, but noted that the Constitution does not permit commitment of a sex offender without some lack-of-control determination.
that he suffers from a "mental abnormality"—a disorder affecting his "emotional or volitional capacity which predisposes the person to commit sexually violent offenses"—or a "personality disorder," either of "which makes the person likely to engage in repeat acts of sexual violence." Kan. Stat. Ann. §§59-29a02(a), (b) (2000 Cum. Supp.).
Several psychologists examined Crane and diagnosed him with exhibitionism
and antisocial personality disorder
. One psychologist concluded that the two diagnoses in combination placed Crane within the listed sexual disorders covered by the SVPA, "cit[ing] the increasing frequency of incidents involving [respondent], increasing intensity of the incidents, [respondent's] increasing disregard for the rights of others, and his increasing daring and aggressiveness." Another psychologist testified that Crane's behavior was marked by "impulsivity or failure to plan ahead," indicating his unlawfulness "was a combination of willful and uncontrollable behavior," id., at 584-585, 7 P. 3d, at 290. The State's experts agreed, however, that "[r]espondent's mental disorder does not impair his volitional control to the degree he cannot control his dangerous behavior." Id., at 581, 7 P. 3d, at 288.
Crane moved for a summary judgment
which was denied by the trial court and gave jury instructions
to the terms of the statute. Id., at 581, 7 P. 3d, at 287-288. The jury found that Crane was a sexual predator as defined by the SVPA. The Kansas Supreme Court reversed, holding the SVPA unconstitutional as Crane had only a personality disorder rather than a volitional impairment. For such a person, it held, the State must show not merely a likelihood that the defendant would engage in repeat acts of sexual violence, but also an inability to control violent behavior, based on Kansas v. Hendricks
(1997).
too restrictively when they ruled that a sexual offender, who has only an emotional or personality disorder
, but not a volitional impairment, does not have the ability to control dangerous behavior.
The required standard of proof had to be sufficient to make the distinction between a dangerous sexual offender whose serious mental illness or abnormality, made him eligible for civil commitment from the "dangerous but typical recidivist" offender convicted in an ordinary criminal case. However, the Court concluded that an absolute finding of lack of control
was not necessary, since otherwise there would be a risk of barring the civil commitment of some highly dangerous persons suffering severe mental abnormalities.
after they've served their sentence.
Substantive due process
Substantive due process is one of the theories of law through which courts enforce limits on legislative and executive powers and authority...
. The Court clarified that its earlier holding in Kansas v. Hendricks
Kansas v. Hendricks
Kansas v. Hendricks is a case in which U.S. Supreme Court set forth procedures for the indefinite civil commitment of prisoners convicted of a sex offense whom the state deems dangerous due to a mental abnormality.-Fact of case:...
did not set forth a requirement of total or complete lack of control, but noted that the Constitution does not permit commitment of a sex offender without some lack-of-control determination.
Circumstances
Michael Crane pleaded guilty to aggravated sexual battery for two incidents on the same day in 1993. In the first, Crane exposed himself to a tanning salon attendant. One half hour later, Crane exposed himself to the clerk in a video store and demanded she perform oral sex on him, threatening to rape her before leaving. After Crane's guilty plea, the State petitioned to have Crane evaluated and adjudicated a sexual predator under Kansas' SVPA which permits the civil detention of a person convicted of any of several listed sexual offenses, if it can be proven beyond a reasonable doubtReasonable doubt
Proof beyond a reasonable doubt is the standard of evidence required to validate a criminal conviction in most adversarial legal systems . Generally the prosecution bears the burden of proof and is required to prove their version of events to this standard...
that he suffers from a "mental abnormality"—a disorder affecting his "emotional or volitional capacity which predisposes the person to commit sexually violent offenses"—or a "personality disorder," either of "which makes the person likely to engage in repeat acts of sexual violence." Kan. Stat. Ann. §§59-29a02(a), (b) (2000 Cum. Supp.).
Several psychologists examined Crane and diagnosed him with exhibitionism
Exhibitionism
Exhibitionism refers to a desire or compulsion to expose parts of one's body – specifically the genitals or buttocks of a man or woman, or the breasts of a woman – in a public or semi-public circumstance, in crowds or groups of friends or acquaintances, or to strangers...
and antisocial personality disorder
Antisocial personality disorder
Antisocial personality disorder is described by the American Psychiatric Association's Diagnostic and Statistical Manual, fourth edition , as an Axis II personality disorder characterized by "...a pervasive pattern of disregard for, and violation of, the rights of others that begins in childhood...
. One psychologist concluded that the two diagnoses in combination placed Crane within the listed sexual disorders covered by the SVPA, "cit[ing] the increasing frequency of incidents involving [respondent], increasing intensity of the incidents, [respondent's] increasing disregard for the rights of others, and his increasing daring and aggressiveness." Another psychologist testified that Crane's behavior was marked by "impulsivity or failure to plan ahead," indicating his unlawfulness "was a combination of willful and uncontrollable behavior," id., at 584-585, 7 P. 3d, at 290. The State's experts agreed, however, that "[r]espondent's mental disorder does not impair his volitional control to the degree he cannot control his dangerous behavior." Id., at 581, 7 P. 3d, at 288.
Crane moved for a summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
which was denied by the trial court and gave jury instructions
Jury instructions
Jury instructions are the set of legal rules that jurors should follow when the jury is deciding a civil or criminal case. Jury instructions are given to the jury by the jury instructor, who usually reads them aloud to the jury...
to the terms of the statute. Id., at 581, 7 P. 3d, at 287-288. The jury found that Crane was a sexual predator as defined by the SVPA. The Kansas Supreme Court reversed, holding the SVPA unconstitutional as Crane had only a personality disorder rather than a volitional impairment. For such a person, it held, the State must show not merely a likelihood that the defendant would engage in repeat acts of sexual violence, but also an inability to control violent behavior, based on Kansas v. Hendricks
Kansas v. Hendricks
Kansas v. Hendricks is a case in which U.S. Supreme Court set forth procedures for the indefinite civil commitment of prisoners convicted of a sex offense whom the state deems dangerous due to a mental abnormality.-Fact of case:...
(1997).
Decision
The court decided, in a split 7–2 opinion that the Constitution does not permit commitment of the type of dangerous sexual offender considered in Hendricks without any lack-of-control evaluation. They concluded that the Kansas Supreme Court interpreted Kansas v. HendricksKansas v. Hendricks
Kansas v. Hendricks is a case in which U.S. Supreme Court set forth procedures for the indefinite civil commitment of prisoners convicted of a sex offense whom the state deems dangerous due to a mental abnormality.-Fact of case:...
too restrictively when they ruled that a sexual offender, who has only an emotional or personality disorder
Personality disorder
Personality disorders, formerly referred to as character disorders, are a class of personality types and behaviors. Personality disorders are noted on Axis II of the Diagnostic and Statistical Manual of Mental Disorders or DSM-IV-TR of the American Psychiatric Association.Personality disorders are...
, but not a volitional impairment, does not have the ability to control dangerous behavior.
The required standard of proof had to be sufficient to make the distinction between a dangerous sexual offender whose serious mental illness or abnormality, made him eligible for civil commitment from the "dangerous but typical recidivist" offender convicted in an ordinary criminal case. However, the Court concluded that an absolute finding of lack of control
Self control
Self control is the ability to control one's emotions, behavior and desires in order to obtain some reward later. In psychology it is sometimes called self-regulation...
was not necessary, since otherwise there would be a risk of barring the civil commitment of some highly dangerous persons suffering severe mental abnormalities.
Significance
This ruling will make it substantially more difficult for States to place sex offenders in civil confinementCivil confinement
Civil confinement is a controversial procedure permitted by a law passed in New York, advocated by the former governor, Eliot Spitzer, allowing the civil commitment of sex offenders because they are deemed by a court to be a danger to themselves or to society. One political commentator on the topic...
after they've served their sentence.
See also
- United States v. ComstockUnited States v. ComstockUnited States v. Comstock, 560 U.S. ___ was a decision by the Supreme Court of the United States, which ruled that the federal government has authority under the Necessary and Proper Clause to require the civil commitment of individuals already in Federal custody...
- List of United States Supreme Court cases, volume 534
- List of United States Supreme Court cases