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Abstract: 

Our review of recent appellate decisions includes In re Commitment of Renshaw, in which the Texas Court of Appeals rejected as frivolous a petition for release from civil commitment made by an offender who had yet to meaningfully participate in mandated treatment; Timms v. U. S. Attorney General, a case from the 4th Circuit ruling that a sex offender’s conviction and imprisonment for a crime committed while he was civilly committed did not terminate that civil commitment; in United States v. Parsons, the 9th Circuit found that polygraph condition required only that the offender submit to a polygraph but no requirement that he answer all of the questions posed during that polygraph; in Alvarado v. State, Wyoming’s highest court ruled that the state’s 10-year period of sex offender registration before a petition to terminate can be filed starts at the time a sentence of probation; in Doe v. Sex Offender Registry Board, a Massachusetts appellate decision that no error was found in a Massachusetts Sex Offender Registry Board’s finding that a sex offender should be classified as a level three sex offender after a hearing examiner had engaged in the required qualitative and objective review that balanced all the relevant risk-aggravating and mitigating factors; two New York rulings on point assessment, People v. Jones and People v. McNeill, were both upheld on appeal as properly made; in Skehan v. Idaho State Police, the state’s appellate court ruled that Idaho’s Central Sex Offender Registry was not required to compare an offender’s Oregon conviction to Idaho offenses that did not require registration; and decisions on commitment under California’s Sexually Violent Predator Act, and categorical ineligibility for medical parole.

Keywords: Civil Commitment; Polygraphs; Sex Offender Registration; Sex Offender Classification; Point Assessment; SVP Designation; Categorical Ineligibility for Medical Parole

Affiliations:  1: Sex Offender Law Report.