Kansas v. Crane
| Kansas v. Crane | |
|---|---|
|
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| Argued October 30, 2001 Decided January 22, 2002 |
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| Full case name | Kansas, Petitioner v. Michael T. Crane |
| Citations | 534 U.S. 407 (more) |
| Holding | |
| The Constitution does not permit commitment of the type of dangerous sexual offender considered in Hendricks without determining the offender lacks self control. | |
| Court membership | |
| Case opinions | |
| Majority | Breyer, joined by O'Connor, Kennedy, Souter, Ginsburg, Rehnquist, Stevens |
| Dissent | Scalia, joined by Thomas |
| Laws applied | |
| U.S. Const. amend. VIII | |
Kansas v. Crane, 534 U.S. 407 (2002) 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.
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 doubt 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.
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