United States v. Timm, No. 11-6886 (4th Cir. 2012)
Annotate this CaseThe government appealed from the judgment of the district court dismissing its action to civilly commit respondent as a "sexually dangerous person" under 18 U.S.C. 4248. The district court held that the statute as applied to respondent violated the Due Process and Equal Protection Clauses of the Constitution and respondent cross-appealed. The court reversed the district court's judgment dismissing the government's commitment action; the district court did not err in concluding that section 4248 was a civil statute and thus was not subject to the various constitutional safeguards placed on criminal proceedings; nor did it err in relying on this court's precedent that section 4248's requirement that proof of past conduct by "clear and convincing evidence" rather than "beyond a reasonable doubt" was appropriate; and circuit precedent also foreclosed respondent's argument that section 4248 could not be invoked because his criminal sentence included post-incarceration supervised release. However, the district court erred in finding that, as applied to respondent, section 4248 deprived him of equal protection and due process of law. The case was remanded for the district court to determine on the merits whether respondent met the section 4248 criteria.
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