In RE the Detention of Jonathan Edwin Stenzel Jonathan Edwin Stenzel, 827 N.W.2d 690

Stenzel, convicted of multiple offenses, is civilly committed as a sexually violent predator (SVP) under Iowa Code chapter 229A after a murder-like sequence of offenses while imprisoned.
The State filed an SVP petition while Stenzel remained in prison with a current term including a sexually violent offense, raising timeliness questions.
The district court denied motions to dismiss and for summary judgment; trial proceeded to a jury, which found Stenzel to be an SVP.
Dr. Leavitt testified Stenzel has paraphilia, antisocial personality disorder, and that he is likely to reoffend if not confined; actuarial tools were used to support risk.
Stenzel objected to admitting testimony about the SVP selection process and about prior offenses based on minutes and records, arguing hearsay and Rule 5.703 limitations.
The Supreme Court affirms timeliness and sufficiency of evidence but reverses for the improper admission of evidence about the State’s selection process, remanding for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of SVP petition	Stenzel contends no present confinement for SVP; time exceeded.	State argues ongoing confinement includes a sexually violent offense; petition timely.	Petition timely; present confinement exists when current term includes a SVP offense.
Sufficiency of evidence to prove SVP	Stenzel asserts insufficient evidence to show mental abnormality and future risk.	State presents substantial evidence including Dr. Leavitt's diagnosis and risk tools.	Substantial evidence supports finding of SVP.
Admissibility of State’s selection-process testimony	Leavitt’s testimony about the screening process is hearsay and beyond proper 5.703 bases.	Testimony relies on generally used expert methods; admissible under 5.703 as reasonably relied.	Reversed for improper admission of selection-process testimony; remanded for new trial.

In re Detention of Gonzales, 658 N.W.2d 102 (Iowa 2003) (defined confinement as confinement for a sexually violent offense)
In re Detention of Shaffer, 769 N.W.2d 169 (Iowa 2009) (presently confined inquiry not hypertechnical)
In re Detention of Willis, 691 N.W.2d 726 (Iowa 2005) (allowed petition without a recent overt act under confinement theory)
State v. Patterson, 586 N.W.2d 83 (Iowa 1998) (consecutive sentences treated as confinement period for administrative purposes)
State v. Kapell, 510 N.W.2d 878 (Iowa 1994) (administrative ease in sentencing consecutive terms)