Morel v. Wilkins
84 So. 3d 226
| Fla. | 2012Background
- Ronald Morel, convicted of sexually violent offenses, was detained awaiting Jimmy Ryce civil commitment following release from prison in 2002.
- Morel waived the statutory 30-day trial deadline in 2002; his commitment trial was delayed for nearly eight to ten years while in pretrial detention at FCCC under DCF custody.
- DCF contracted with GEO to operate FCCC’s sexual offender treatment program; pretrial detainees historically had limited access to the comprehensive four-phase SOTP.
- A 2005-2009 shift in providers and program structure culminated in Phase I access for detainees but exclusion from Phases II–IV; adjunct therapies remained available to detainees.
- Morel filed habeas petitions alleging due process/equal protection violations and seeking release or full treatment access; a two-day evidentiary hearing occurred in the circuit court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pretrial detainees have a constitutional right to full SOTP treatment. | Morel contends detainees must receive full SOTP access under due process. | Morel is not entitled to full treatment; Youngberg allows professional judgment and not required to provide all phases before commitment. | No due process entitlement to full SOTP for noncommitted detainees. |
| Whether delays in treatment/trial render the FCCC program unconstitutional. | Delays undermine treatment opportunities and prolong detention unconstitutionally. | Delays are justified; program operates with rational professional judgment and no unconstitutional defect. | Delays do not render the program unconstitutional; waits are supported by professional judgment and program structure. |
| Whether the nearly decade-long pretrial detention violates due process laws. | Eight-year delay is presumptively prejudicial and unlawful. | Delay was at Morel's own request and should be examined under Barker v. Wingo factors; no presumptive prejudice. | Delay not unconstitutional; Morel caused or tolerated the delay and lacks prejudice under Barker factors. |
| What jurisdiction/venue is proper for habeas challenges to pretrial delay under the Ryce Act. | Murray v. Regier precedent may constrain jurisdiction; Morel seeks relief where detention occurs. | Circuit where detention occurs or where commitment trial is pending has proper authority; Murray should be reconciled. | Relief affirmed in related context; Court emphasizes appropriate jurisdiction and seeks procedures to minimize delay; recedes from some Murray aspects. |
Key Cases Cited
- Youngberg v. Romeo, 457 U.S. 307 (U.S. (1982)) (state has discretion in treatment decisions for institutionalized individuals; minimal due process scrutiny)
- Hendricks v. Kansas, 521 U.S. 357 (U.S. (1997)) (states may civilly detain untreatable but dangerous offenders; broad discretion in treatment regimes)
- Seling v. Young, 531 U.S. 250 (U.S. (2001)) (due process requires confinement conditions/duration bear relation to purpose of commitment)
- Goode v. Os-zgoode, 830 So.2d 822 (Fla. 2002) (scrupulous compliance with 30-day trial deadline; indefinite detention rejected)
- Kinder v. Goode, 830 So.2d 832 (Fla. 2002) (indefinite detention contrary to due process; use of timely proceedings)
- Osborne v. State, 907 So.2d 505 (Fla. 2005) (remedy for violation of thirty-day limit when trial未 timely; release if continuance improper)
- Murray v. Regier, 872 So.2d 217 (Fla. 2002) (habeas for pretrial detention; jurisdictional concerns; right to timely relief)
- Doggett v. United States, 505 U.S. 647 (U.S. (1992)) (presumptively prejudicial delay triggers Barker factors for speedy-trial claims)
- Barker v. Wingo, 407 U.S. 514 (U.S. (1972)) (four-factor framework for evaluating speedy-trial claims; prejudice assessment)
- Foucha v. Louisiana, 504 U.S. 71 (U.S. (1992)) (core due process protection in confinement and liberty interests)