Kansas v. Crane

Brief Fact Summary.

Kansas appealed after the state supreme court determined that they must prove that the defendant could not control his dangerous behavior in order to civilly commit Crane.

Synopsis of Rule of Law.

A state must prove that a defendant cannot control his behavior and his behavior is a threat to the public to civilly commit that individual.

Facts.

Crane was a previously convicted sex offender and the state sought his commitment. After a trial with the district court, Crane was ordered to be committed, but the state supreme court preempted his commitment claiming that there needed to be a finding that Crane could not control his dangerous behavior, as determined by Kansas v. Hendricks, 521 U.S. 346 (1997). The state appealed to the United States Supreme Court and the Supreme Court granted certiorari.

Issue.

Whether a state needs to prove that a defendant cannot control his behavior in order to civilly commit that defendant?

Held.

No. The state is not required to prove that the defendant has lost total control over his behavior. The defendant is only required to have little control over his behavior and the behavior must be a danger to society. The judgment of the state supreme court is vacated and remanded.

Dissent.

(Scalia, J.) Many people have control over their behavior but also have impulses that are difficult to overcome. The standard of proof that requires the state to exhibit a defendant’s control over their behavior is insufficient to determine whether a defendant should be committed, and the state should look at the defendant’s mental state instead.

Discussion.

Under Hendricks, a sex offender who cannot control his criminal behavior should be ordered to be committed while those sex offenders who have control over their criminal behavior should be treated as criminals within the criminal justice system. The state is only required to prove that the defendant has serious difficulty in controlling his criminal behavior and the standard that requires the state to prove that the defendant completely lacks control over his behavior is too harsh of a burden to overcome.