People v. Ingram
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In 2017, Michael Ingram was found to be a sexually violent predator (SVP) and committed to the State Department of State Hospitals (DSH) for an indeterminate term under the Sexually Violent Predator Act (SVPA). In 2020, he filed a petition for conditional release, arguing he was not likely to engage in sexually violent criminal behavior if released under supervision and treatment in the community. The trial court denied his petition, and Ingram appealed, challenging both the trial court’s decision and the constitutionality of the SVPA’s conditional release provisions.
The Superior Court of Sacramento County initially handled the case, where a jury found Ingram to be an SVP. Ingram then filed a petition for conditional release, which the trial court denied. The court found that Ingram had not made significant progress in his treatment program and that his risk to the community remained unchanged. The court also noted that while Ingram might receive better treatment in the community, the issue before the court was whether he could be safely released, not whether he could receive better treatment elsewhere.
The California Court of Appeal, Third Appellate District, reviewed the case. The court affirmed the trial court’s decision, finding that substantial evidence supported the denial of Ingram’s petition. The appellate court noted that all experts agreed Ingram continued to meet the definition of an SVP and that he had not yet learned to control his sexually violent behavior. The court also found that Ingram’s proposed alternative conditional release program, which included 24/7, one-on-one supervision, was neither reasonable nor required by the SVPA. Additionally, the court rejected Ingram’s constitutional challenges, noting that these issues were not properly raised in the lower court and that Ingram lacked standing to challenge potential delays in finding housing for conditionally released SVPs.
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