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Abstract: 

The Supreme Court’s decision in Kansas v. Crane, discussed in 5 Sexual Assault Report 5 (May/June 2002), provided additional guidance to courts dealing with the civil commitment of sexually violent offenders under sexual predator laws. According to the Court, under the Kansas statute, offenders must have a mental disorder that manifests in a “serious lack of ability to control behavior” for commitment to be constitutionally permitted. The Court did not provide a bright-line rule, and as lower courts seek to apply the newly announced standard, differences of opinion are already surfacing.

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