In re Care & Treatment of WilliamsAnnotate this Case
Darwin Williams was convicted in 1987 of two counts of indecent liberties with a child pursuant to state law and sentenced to five to twenty years’ imprisonment. In May, 1998, Williams was paroled, but six months later, his parole was revoked because of drug use. After serving more time in prison, Williams was paroled in June 2002, but that parole was revoked six months later. The basis for the second revocation was explained at trial when the State’s expert read from a portion of the Department of Corrections’ Clinical Services Report (CSR). The CSR indicated that Williams’ parole was revoked “for having sexual contact with a minor, consuming alcohol, unsuccessful discharge from a Sex Offender Treatment Program, and admitting to viewing pornographic/sexually explicit materials.” As Williams’s prison term neared its end, the State filed a petition requesting the civil commitment of Williams as a sexually violent predator. The district court determined that probable cause existed for the allegation and sent Williams to a State hospital for evaluation. The district court also appointed a psychologist to perform an independent evaluation pursuant to state law. At trial, experts gave conflicting opinions regarding whether a mental abnormality or personality disorder made Williams likely to repeat acts of sexual violence. After hearing the testimony, the district court found beyond a reasonable doubt that Williams was a sexually violent predator. The appellate court examined the sole issue raised by Williams on appeal: whether there was sufficient evidence to support the requirement under the state Sexually Violent Predator Act (SVPA) that he was “likely to engage in repeat acts of sexual violence” in that “the person’s propensity to commit acts of sexual violence is of such a degree as to pose a menace to the health and safety of others.” The appellate court found that the evidence was insufficient and reversed the district court. The Supreme Court on review found the evidence was sufficient to conclude a reasonable person could find that the State proved its case beyond a reasonable doubt that Williams was a sexually violent predator, and affirmed the district court’s decision.