Kansas v. Hendricks
| Kansas v. Hendricks | |
|---|---|
|
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| Argued December 10, 1996 Decided June 23, 1997 |
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| Full case name | Kansas v. Leroy Hendricks |
| Citations | 521 U.S. 346 (more) |
| Prior history | Certiorari to the Kansas State Supreme Court |
| Holding | |
| Reverses Kansas State Supreme Court and agrees with the state's procedures for the indefinite civil commitment procedures for sex offenders meeting the definition of a "mental abnormality" upon release from prison | |
| Court membership | |
| Case opinions | |
| Majority | Thomas, joined by Rehnquist, Scalia, O'Connor, Kennedy |
| Dissent | Breyer, joined by Stevens, Souter, Ginsburg |
| Laws applied | |
| Due Process, Miscellaneous; Criminal Procedure, Ex Post Facto | |
Kansas v. Hendricks, 521 U.S. 346 (1997), was a United States Supreme Court case in which the 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.
Under Kansas's Sexually Violent Predator Act (Act), any person who, due to "mental abnormality" or "personality disorder", is likely to engage in "predatory acts of sexual violence" can be indefinitely confined. Leroy Hendricks and Tim Quinn had extensive histories of sexually molesting children. When they were due to be released from prison, Kansas filed a petition under the Act in state court to involuntarily commit Hendricks and Quinn. Hendricks and Quinn challenged the constitutionality of the Act and requested a trial by jury which the court granted. Hendricks and Quinn testified during the trial that they agreed with the diagnosis by the state psychiatrist that Hendricks and Quinn suffer from pedophilia and admitted that they continued to experience uncontrollable sexual desires for children when under extreme stress. The jury decided that they qualified as sexually violent predators. Since pedophilia is defined as a mental abnormality under the Act, the court ordered that Hendricks be civilly committed.
Hendricks appealed the validity of his commitment as well as claiming that the state was unconstitutionally using ex post facto and double jeopardy law, to the State Supreme Court. The court ruled that the Act was invalid on the grounds that the condition of "mental abnormality" did not satisfy the "substantive" due process requirement that involuntary civil commitment must be based on the finding of the presence of a "mental illness". It did not address the claims of ex post-facto and double jeopardy.
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