Matter of R.A.S.Annotate this Case
R.A.S. was convicted of gross sexual imposition in 1991 and sentenced to eight years. In 2001 R.A.S. was convicted of possession of stolen property, and in 2002 assault on a corrections officer. As part of the sentence for the possession of stolen property charge, the district court recommended R.A.S. receive a mental health evaluation. Before his scheduled release in 2004, the State successfully petitioned to commit R.A.S. as a sexually dangerous individual. R.A.S. appealed denial of his petition for discharge and continuing commitment as a sexually dangerous individual. The North Dakota Supreme Court found the order denying R.A.S.’s petition for discharge lacked findings sufficient to satisfy the due process requirement under Kansas v. Crane, 534 U.S. 407 (2002).