Taylor v. San Diego Cnty., No. 12-55030 (9th Cir. 2015)
Annotate this CasePetitioner seeks federal habeas corpus relief from a state-court order committing him indefinitely for involuntary treatment as a sexually violent predator, in accordance with California law. The court concluded that the California Court of Appeal did not unreasonably apply clearly established federal law to petitioner’s equal protection claim by determining that sexually violent predators are not similarly situated to other civilly committed offenders. The court rejected petitioner's argument that individuals who are committed under the Lanterman-Petris Short (LPS) Act, California Welfare and Institutions Code 5000 et seq., are similarly situated to those committed under the Sexually Violent Predator Act (SVPA), California Welfare and Institutions Code 6604. Further, petitioner's due process challenge must fail because no Supreme Court precedent prohibited amendments to the SVPA to change the burden to the detainee to establish the right to release. Accordingly, the court affirmed the district court's denial of habeas corpus relief to petitioner.
Court Description: Habeas Corpus. The panel affirmed the district court’s denial of a habeas corpus petition challenging a state-court order committing the petitioner indefinitely for involuntary treatment as a sexually violent predator. The panel held that the district court did not err in denying a claim that California’s Sexually Violent Predator Act violates the Equal Protection Clause because it contains release procedures that are more onerous than those placed on other civilly committed detainees. The panel concluded that individuals committed under California’s Lanterman-Petris Short Act were not similarly situated to those committed under the SVPA. The panel held that, given the absence of established Supreme Court precedent, the district court also did not err in TAYLOR V. SAN DIEGO CTY. 3 denying a claim that the SVPA violates the Due Process Clause because it contains a burden-shifting scheme requiring the detainee to prove that he is no longer a sexually violent predator in order to terminate his commitment.
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