In Re the Detention of David L. Taft Jr. David L. Taft Jr.
15-1732
| Iowa Ct. App. | Mar 22, 2017Background
- David Taft Jr. was civilly committed in 2005 as a sexually violent predator after prior sexual convictions and a jury finding he had a mental abnormality making reoffense likely.
- The commitment program requires annual review and, if a committed person meets certain criteria, possible discharge or placement in a transitional release program; there is a rebuttable presumption in favor of continued commitment.
- After Taft’s 2014 annual review he was granted a final hearing under Iowa Code §229A.8(6); the final hearing occurred in September 2015 with competing expert testimony about his risk to reoffend and adequacy of his relapse prevention plan.
- The jury found Taft’s mental abnormality had not changed and he was not suitable for discharge or for placement in the transitional release program.
- Taft appealed, challenging (1) jury instructions about the State’s burden of proof and the transitional-release eligibility criteria, and (2) the district court’s admission of evidence that his relapse prevention plan was inadequate despite a prior State concession at the annual-review stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Burden of proof instruction ("likely" = "more likely than not") | Taft: "more likely than not" equates to preponderance and conflicts with Addington requiring a higher standard | State: Iowa law requires proof beyond a reasonable doubt at final hearing; statutory definition of "likely" means more probable than not and does not lower constitutional standard | Court: Instruction permissible because Iowa requires beyond-a-reasonable-doubt and defining "likely" as "more likely than not" does not dilute that burden (citing Williams) |
| Transitional-release preconditions wording ("high risk") | Taft: "high risk" is undefined and confusing to jury | State: Instruction mirrors statutory criteria and must be read as a whole with other definitions | Court: No error; instruction follows statute and read with definitions (e.g., "mental abnormality") is not confusing |
| Relapse-prevention-plan issue: effect of State’s earlier concession | Taft: State previously agreed plan was approved for purposes of final-hearing entitlement, so State should be precluded from contesting adequacy at final hearing | State: Earlier concession applied only to whether a final hearing was warranted (preponderance stage), not to the final-hearing burden beyond a reasonable doubt | Court: No abuse of discretion; the concession did not bind the State at the final hearing and evidence about plan adequacy was admissible |
| Six-month major-discipline-report timing | Taft: He lacked a major report for six months and thus that factor should not go to jury | State: Two distinct six-month windows apply (one for showing entitlement to final hearing; another for eligibility at the final hearing) | Court: No error; evidence of discipline reports during the six months before the final hearing was properly submitted to the jury |
Key Cases Cited
- Addington v. Texas, 441 U.S. 418 (U.S. 1979) (civil commitment requires a heightened burden of proof)
- In re Det. of Williams, 628 N.W.2d 447 (Iowa 2001) (defining "likely" as "more likely than not" does not diminish a high proof standard when statute requires beyond a reasonable doubt)
- Taft v. Iowa Dist. Ct., 828 N.W.2d 309 (Iowa 2013) (procedural standards for annual review and final hearing)
- Taft v. Iowa Dist. Ct., 879 N.W.2d 634 (Iowa 2016) (ripeness and preservation issues regarding statutory criteria challenges)
- In re Det. of Shaffer, 769 N.W.2d 169 (Iowa 2009) (standard of appellate review in detention matters)
- In re Det. of Matlock, 860 N.W.2d 898 (Iowa 2015) (de novo review for constitutional claims in detention cases)
- In re Det. of Brooks, 973 P.2d 486 (Wash. 1999) (persuasive authority that "likely" may be defined as "more probable than not" without reducing proof required where higher standard applies)