Kansas v. Crane

Background

The State of Kansas sought to civilly commit Michael Crane, a previously convicted sex offender diagnosed with exhibitionism and antisocial personality disorder. A jury found him eligible under Kansas’s Sexually Violent Predator Act and a trial court ordered his detention. The Kansas Supreme Court reversed, saying the Constitution required a finding that the person cannot control his dangerous behavior.

Reasoning

The Supreme Court reviewed its earlier decision in Hendricks and held that Hendricks did not demand proof of complete or total lack of control. Instead, the Court said the Constitution requires proof of a serious difficulty in controlling dangerous behavior. The majority emphasized that this standard must distinguish civil commitment from ordinary criminal punishment and prevent commitment from becoming mere retribution or deterrence. The Court also noted that psychiatry is not exact and that States have leeway in defining qualifying mental conditions.

Real world impact

The Court vacated the Kansas Supreme Court’s ruling and sent the case back for further proceedings consistent with this clarification. States that use similar civil commitment laws can proceed without proving absolute inability to control behavior, but must still show significant control problems tied to a recognized mental abnormality or disorder. The decision gives trial courts and juries a flexible constitutional test rather than a rigid bright-line rule.

Dissents or concurrances

Justice Scalia dissenting argued the Court misread Hendricks, would have left the statute as applied, and protested creating uncertainty about how juries should be instructed.