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United States v. Comstock

    Brief Fact Summary.

    The federal government appealed after the district court ruled that a law allowing the government to hold a sexually deviant prisoner past his sentence exceeded the powers of Congress.

    Synopsis of Rule of Law.

    Under the Necessary and Proper Clause, Congress has the authority to hold the mentally ill and the sexually dangerous past their maximum prison sentences.

    Facts.

    18 U.S.C. § 4248 allows a district court to detain a mentally ill, sexually dangerous individual beyond their prison sentences with evidence that the person has engaged in sexually violent behavior, is mentally ill, and sexually dangerous. Grayson Comstock, Jr. and other inmates pled guilty to crimes involving sexual abuse of a minor and claimed that the federal law was unconstitutional. The district court ruled that the law exceeded the authority of Congress and the Court of Appeals affirmed.

    Issue.

    Whether Congress has the authority to hold the mentally ill, and the sexually dangerous past their sentences?

    Held.

    Yes. The Necessary and Proper Clause vests power in Congress that is indicative of their enumerative powers. The decision in the court of appeals is reversed.

    Dissent.

    (Thomas, J.) No enumerated power exists that allows the federal government to civilly commit a federal prisoner. 18 U.S.C. § 4248 is only constitutional if it expands on another enumerated power. Civil commitment is an exercise of state police power.

    Concurrence.

    (Alito, J.) The statute is constitutional because the states should not be required to carry the burden of the federal criminal justice system or federal prisoners.

    Discussion.

    Congress has the authority to control federal prisons and therefore maintains authority over federal inmates. Also, the mental illness framework used in the federal law is only an extension of civil commitment legislation that has existed since the nineteenth century. The statute does not interfere with state powers because the law orders inmates to be under state control if the individual state asserts their authority.


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