In re Commitment of Fields, 2014 IL 115542

Justin Fields was convicted in 2005 of aggravated criminal sexual abuse and kidnapping involving a nine-year-old; earlier in 2000 he committed a separate sexual offense against a nine-year-old.
The State petitioned under the Sexually Violent Persons Commitment Act (SVP Act); after a jury trial in March 2011 two experts testified Fields suffers from pedophilia and antisocial personality disorder and is substantially likely to reoffend. Fields offered no trial evidence.
The jury found Fields an SVP; immediately after the verdict the trial judge entered judgment and ordered commitment to a secure treatment facility without conducting a separate dispositional hearing.
Fields requested a date for a dispositional hearing and a pre-hearing evaluation; the court refused, ruling it had sufficient information from trial to make disposition.
The appellate court affirmed the SVP finding but vacated the commitment order and remanded for a dispositional hearing. The Illinois Supreme Court affirmed the appellate court on both sufficiency and the dispositional-hearing requirement.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Fields)	Held
Sufficiency of evidence that Fields is an SVP	Expert diagnoses and actuarial/clinical risk assessments based on convictions, records, interviews suffice	Diagnosis flawed because one offending incident occurred when Fields was under 16, undermining pedophilia diagnosis and the SVP finding	Evidence sufficient; jury could credit experts and DSM-IV-TR application; SVP finding affirmed
Whether court violated SVP Act by failing to hold dispositional hearing	Trial court may make disposition immediately if it has sufficient information; denying a continuance is permissible	Court refused to hold the statutorily required dispositional hearing and denied opportunity to present dispositional evidence	Commitment order vacated and remanded: statute requires a dispositional hearing and none was convened; remand for dispositional hearing required

People v. Amigon, 239 Ill. 2d 71 (discusses statutory construction and legislative intent)
People v. Collins, 214 Ill. 2d 206 (statutory construction principles; review de novo)
In re Detention of Varner, 315 Ill. App. 3d 626 (discusses discretionary continuance of dispositional hearing under SVP Act)
People v. Winterhalter, 313 Ill. App. 3d 972 (upheld disposition without continuance where court gave opportunity to present dispositional evidence)
In re Detention of Tittlebach, 324 Ill. App. 3d 6 (court did not abuse discretion in committing where sufficient information existed)