In Re the Detention of Deon Teon Campbell, 15-0507

Respondent Deon Campbell, with prior convictions including third-degree sexual abuse, was subject to a 2012 petition seeking civil commitment under Iowa Code chapter 229A as a sexually violent predator.
Campbell has a history of prison sexual infractions and was dismissed from sex-offender treatment for sexually explicit conduct.
At the 2015 bench trial (Campbell waived a jury), the State’s expert diagnosed "other specified personality disorder with anti-social features" and opined Campbell was highly likely to reoffend; Campbell’s expert disputed the diagnosis and concluded he did not have a mental abnormality.
The district court found the State’s expert more credible, relying on specific past conduct, treatment noncompletion, prison infractions, and Campbell’s minimizations and rationalizations, and ordered civil commitment.
Campbell appealed, arguing that the diagnosis of "other specified personality disorder" was too vague to satisfy the statutory definition of a mental abnormality and thus violated substantive due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a diagnosis of "other specified personality disorder" can satisfy chapter 229A's mental abnormality requirement	Campbell: the diagnosis is vague and insufficient to show a congenital/acquired condition affecting emotional or volitional capacity that predisposes to sexual violence	State: the diagnosis, supported by expert testimony and specific conduct, shows an acquired condition affecting emotional/volitional capacity and a propensity to reoffend	Affirmed — court held the diagnosis, supported by specific conduct and credible expert testimony, established a qualifying mental abnormality
Whether evidence sufficed to show likelihood to reoffend (predisposition to commit sexually violent offenses)	Campbell: expert testimony failed to demonstrate likelihood; risk instruments and diagnosis were inadequate	State: expert testimony, actuarial risk, treatment refusal/noncompletion, prison sexual infractions, and Campbell’s rationalizations support likelihood	Affirmed — district court’s credibility determinations and the cited facts provided sufficient evidence of likely reoffense

In re Detention of Barnes, 689 N.W.2d 455 (Iowa 2004) (defining mental abnormality and standard for civil commitment under chapter 229A)
State v. Jacobs, 607 N.W.2d 679 (Iowa 2000) (deference to district court on credibility when experts conflict)