In re the Detention of Stanbridge
Annotate this CaseStanbridge served time for aggravated criminal sex abuse concerning a 1999 Adams County; Lieberman was convicted of multiple Cook County counts of rape in 1980. Both were committed to the Department of Human Services under the Sexually Violent Persons Commitment Act (725 ILCS 207/1), which establishes a framework under which persons who have been convicted of certain sex offenses may be subjected to further civil detention after service of their criminal sentences. Their petitions for release were dismissed by the circuit courts. In Stanbridge’s case, the appellate court reversed, but as to Lieberman, dismissal was affirmed. The Illinois Supreme Court affirmed (reinstated) dismissal of the petitions, clarifying the evidence required at post-commitment hearings for discharge or release. There must be a plausible account on each of the required elements of the petition, demonstrating a change in the circumstances that led to the initial commitment. The burden of proof is on the petitioner to bring forward sufficient evidence. In both of the proceedings at issue, the evidence did not, essentially, present anything new; there was no “plausible account” showing that the individual should no longer be civilly committed as sexually violent.
Court Description:
This consolidated case involves appeals by two individuals, Kevin Stanbridge and Brad Lieberman, who have been committed to the Department of Human Services under the Sexually Violent Persons Commitment Act (725 ILCS 207/1 et seq.). The Act establishes a framework under which persons who have been convicted of certain sex offenses may be subjected to further civil detention after service of their criminal sentences. Kevin Stanbridge served time on an aggravated criminal sex abuse conviction concerning a 1999 offense in Adams County, and Brad Lieberman was convicted of multiple Cook County counts of rape in 1980. Later, the State was successful in having both of them subjected, subsequent to service of their sentences, to confinement under the Act. Both of them made attempts to be discharged or conditionally released, but their petitions were dismissed by the respective circuit courts. In Stanbridge’s case, the appellate court reversed, but as to Lieberman, the dismissal was affirmed.
In this decision, the Illinois Supreme Court sought to clarify the quantum and scope of evidence required at such postcommitment hearings for discharge or release. In doing so, it relied on its earlier decision in In re Detention of Hardin, 238 Ill. 2d 33 (2010). There, a probable cause standard, rather than a reasonable doubt standard, was established. There must be a plausible account on each of the required elements of the petition to assure the court that there is a substantial basis for the petition by demonstrating a change in the circumstances that led to the initial commitment. The burden of proof in the proceedings is on the petitioner to bring forward sufficient evidence.
The supreme court said that, in both of these postcommitment proceedings, the evidence offered did not, essentially, present anything new. In other words, there was no “plausible account” showing that the individual should no longer be civilly committed as sexually violent.
The circuit court dismissals were upheld in each case. The appellate court’s reversal of the Stanbridge dismissal was reversed, but its affirmance of the Lieberman dismissal was upheld.
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