Seeboth v. Allenby, No. 12-17062 (9th Cir. 2015)
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Petitioner filed suit claiming that California’s Sexually Violent Predator Act (SVPA), Cal. Welf. & Inst. Code 6600–6609.3, is unconstitutional on its face. Petitioner contended that the absence of a provision setting forth a time within which to hold a trial extending the term of his commitment denies him equal protection of the laws because, under California law, other
civilly committed persons have a statutory right to a recommitment trial within a specified period. The court concluded that state courts reasonably may apply the rational basis test when considering equal protection challenges to civil commitment laws; because state courts held that SVPs are not similarly situated to mentally disordered offenders (MDOs) and individuals found not guilty by reason of insanity (NGIs) for the purpose of challenging the lack of a timing provision in the SVPA, that holding amounts to a determination that the state has a constitutionally sufficient reason for treating the groups differently; even assuming equal rates of recidivism, it is not unreasonable to conclude that a state rationally may decide that sexually violent crime is qualitatively more dangerous than other kinds of violent crime; and it was not objectively unreasonable for the state courts to hold that the lack of a timing provision in the SVPA does not deprive SVPs of equal protection of the laws. Accordingly, the court affirmed the district court's denial of habeas corpus relief.
Court Description: Habeas Corpus. The panel affirmed the district court’s denial of a habeas corpus petition asserting that the absence of a provision in California’s Sexually Violent Predator Act (SVPA) setting forth a time within which to hold a trial extending the term of commitment is facially unconstitutional. The petitioner claimed that the lack of a timing provision for sexually violent predators (SVPs) violates the Equal Protection Clause of the Fourteenth Amendment because, under California law, other civilly committed persons – mentally disordered offenders and individuals found not guilty by reason of insanity – have a statutory right to a recommitment trial within a specified period. The state courts held that SVPs are not similarly situated to mentally disordered offenders and individuals found not guilty by reason of insanity for the purpose of challenging the lack of a timing provision in the SVPA. Reviewing under the Antiterrorism and Effective Death Penalty Act of 1996, the panel did not need to resolve the question of whether a citation by the California Supreme Court to People v. Duvall (In re Duvall), 886 P.2d 1252 (Cal. 1995), constitutes a reasoned decision, and in turn did not need to decide which state court issued the last reasoned decision, because the California Supreme Court and Superior SEEBOTH V. ALLENBY 3 Court decisions in this case share common reasoning that does not apply federal law unreasonably. The panel held that state courts may reasonably apply the rational basis test when considering equal protection challenges to civil commitment laws. The panel held that with respect to the procedural steps in the civil commitment process that are at issue here, the state courts reasonably concluded that the state legislature had a rational reason to distinguish between individuals who have been found to be mentally ill and dangerous and individuals who have been found to be mentally ill and sexually dangerous. The panel therefore concluded that it was not objectively unreasonable for the state courts to hold that the lack of a timing provision in the SVPA does not deprive SVPs of equal protection of the laws, and that the California courts did not contravene clearly established federal law.
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