In Re the Detention of Calvin Matlock, Calvin Matlock, 2015 Iowa Sup. LEXIS 27

Calvin Matlock was civilly committed to Iowa’s CCU-SO under the Sexually Violent Predator Act after earlier sexual-offense convictions; he received annual reviews and participated in transitional release programs.
At the 2013 annual review the State could not prove beyond a reasonable doubt that Matlock was likely to reoffend, so the district court granted a directed verdict in favor of Matlock on that issue.
The district court nonetheless found it was in the community’s best interest to release Matlock from CCU-SO "with or without supervision" and ordered DHS to prepare a release plan.
DHS submitted a lengthy release plan (66 primary conditions plus subconditions) that assigned supervision to the DOC; the district court approved those conditions and set six-month reviews.
Matlock appealed, arguing that release with supervision after a finding that he was not likely to reoffend violated his state and federal due process rights.
The Iowa Supreme Court (majority) affirmed release-with-supervision in principle but remanded for a district-court evidentiary hearing because the record did not show the specific conditions were tailored to treatment needs rather than punitive/parole-like restraints.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction/timeliness	Matlock’s appeal from the November 18 order was timely; October order was not final because release-terms remained pending	State argued appeal from October order was untimely	Court held the October order was not final; November 18 order was final and appeal was timely
Constitutionality of release-with-supervision under Due Process	Matlock: once not shown likely to reoffend, any supervised release under §229A.9A violates due process (an unlawful deprivation of liberty)	State: §229A.9A permits conditional release tailored to treatment and public protection; supervision can be civil and nonpunitive	Majority: Statutory scheme is facially constitutional so long as the person still suffers a mental abnormality and supervision is supported by testimony and balances liberty vs. public safety; but remanded because the specific approved conditions were not shown to be appropriately tailored (may be punitive/parole-like); concurrence would have affirmed in full and not address specific conditions

Kansas v. Hendricks, 521 U.S. 346 (U.S. 1997) (upholding civil commitment scheme for sexually violent predators where mental abnormality limits class and focuses on inability to control dangerousness)
Foucha v. Louisiana, 504 U.S. 71 (U.S. 1992) (confinement of mentally ill person who is no longer dangerous violates due process)
Youngberg v. Romeo, 457 U.S. 307 (U.S. 1982) (balance liberty interests against state’s reasons for restraining freedom in civil-commitment contexts)
Zinermon v. Burch, 494 U.S. 113 (U.S. 1990) (substantive due process bars arbitrary government restraints regardless of procedures)
Daniels v. Williams, 474 U.S. 327 (U.S. 1986) (scope of substantive due process principles)
In re Detention of Garren, 620 N.W.2d 275 (Iowa 2000) (chapter 229A is civil, not criminal; prior Iowa treatment of SVP statutes)
State v. Huss, 666 N.W.2d 152 (Iowa 2003) (release conditions for mentally ill persons must aim at treatment; harmless mentally ill cannot be confined)
State v. Stark, 550 N.W.2d 467 (Iowa 1996) (conditional release with treatment-based conditions does not violate due process)
Leonard v. State, 491 N.W.2d 508 (Iowa 1992) (commitment decisions must treat persons in the least restrictive medically appropriate environment)