Kansas v. Crane

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Kansas v. Crane

Argued October 30, 2001
Decided January 22, 2002

Full case name:	Kansas, Petitioner v. Michael T. Crane

Citations:	534 U.S. 407

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

Chief Justice: William Rehnquist
Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer

Case opinions

Majority by: Breyer
Joined by: O'Connor, Kennedy, Souter, Ginsburg, Rehnquist, Stevens

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 held that the Kansas Sexually Violent Predator Act (SVPA) is not consistent with substantive due process if it is applied as written. The court recognized that, five years ago, they upheld the same statute they were now finding unconstitutional in an appeal to the court by Kansas.^[1]

1 Circumstances
2 Decision
3 Significance
4 See also
5 Footnotes

[edit] Circumstances

Michael Crane pleaded guilty to aggravated sexual battery for two incidents on the same day in 1993. In the first, Crame exposed himself to a tanning salon attendant. One half hour later, Crame eexposed himself to the clerk in a video store and demanded she perform oral sex on him, threatening to rape her before leaving. After Crames's guilty plea, the State petitioned to have Crame 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.).^[1]

Crane was evaluated by 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 Cran'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.^[1]

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).^[1]

[edit] 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. Hendricks 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.^[2]

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. The Court concluded that an absolute finding of lack of control was necessary, since otherwise there would be a risk of barring the civil commitment of some highly dangerous persons suffering severe mental abnormalities.^[1]

[edit] Significance

This ruling will make it substantially more difficult for States to place sex offenders in civil confinement after they've served their sentence. ^[3]