Stanbridge v. Scott, No. 14-2114 (7th Cir. 2015)
Annotate this CaseStanbridge is confined in a secured facility under the Illinois Sexually Violent Persons Commitment Act, 725 Ill. Comp. Stat. 207/1, which allows for civil commitment of individuals who have been convicted of a sexually violent offense and who suffer from a mental disorder that predisposes them to future acts of sexual violence. Stanbridge sought a writ of habeas corpus, challenging his 2005 criminal conviction for aggravated criminal sexual abuse. Stanbridge had already served his full sentence for his 2005 conviction. The district court, therefore, dismissed Stanbridge’s petition, concluding that it lacked jurisdiction to consider claims related to Stanbridge’s criminal conviction. The Seventh Circuit affirmed, rejecting Stanbridge’s argument that he remains “in custody” pursuant to his sexual abuse conviction because that conviction serves as a necessary, though not sufficient, predicate for his current confinement. Stanbridge’s civil commitment is merely a collateral consequence of his criminal conviction, insufficient to render Stanbridge in custody pursuant to that conviction.
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