Ronald Taylor v. San Diego County, 800 F.3d 1164

Ronald Taylor, convicted of multiple forcible rapes (1975, 1979, 1989), was civilly committed in 2005 as a "sexually violent predator" under California law.
California’s pre-2006 SVPA required two-year commitments with state proving continued dangerousness beyond a reasonable doubt for extensions; Proposition 83 (2006) changed the statute to allow indefinite commitment with annual reviews.
At initial commitment under the amended statute the state must still prove SVP status beyond a reasonable doubt; annual hospital reports recommend continued commitment, conditional release, or discharge.
If the hospital recommends release but the state opposes, the state must again prove danger beyond a reasonable doubt; if the detained person petitions for conditional release, the petitioner must prove by a preponderance that he is no longer an SVP.
Taylor was found by a jury to remain an SVP after expert testimony diagnosing paraphilia and antisocial personality disorder and predicting high risk of reoffense; he challenged the SVPA on Equal Protection and Due Process grounds in state and federal court.
The federal district court denied habeas relief; on appeal, the Ninth Circuit affirmed under AEDPA, concluding the state courts’ rulings were not contrary to or an unreasonable application of clearly established Supreme Court precedent.

Issue	Plaintiff's Argument (Taylor)	Defendant's Argument (State)	Held
Whether SVPA violates Equal Protection by treating SVPs more onerously than LPS detainees	LPS detainees are similarly situated and receive shorter, renewable terms; SVPA’s indefinite commitment denies equal protection (relies on Baxstrom/Jackson)	SVPs and LPS detainees are not similarly situated: SVPs have sexual criminal histories and heightened risk; statute is tailored to compelling public safety interest	Court held SVPs are not similarly situated to LPS detainees; state court decision reasonable and affirmed
Whether SVPA’s release procedures violate Due Process by shifting burden to detainee to prove by preponderance he is no longer dangerous	Addington requires at least clear-and-convincing standard; Jones did not approve procedures that shift burden to detainee for release; SVPA impermissibly shifts burden	No Supreme Court precedent clearly requires the state to bear the burden at re-commitment/release; Jones upheld review procedures with detainee burden; Addington addressed initial commitment only	Court held no clearly established Supreme Court law forbids SVPA’s burden-shifting for release; state court’s denial of due process claim was not unreasonable

Jones v. United States, 463 U.S. 354 (Supreme Court) (upheld review procedures allowing detainee to seek release by proving recovery)
Addington v. Texas, 441 U.S. 418 (Supreme Court) (addressed state burden for initial civil commitment standard)
Baxstrom v. Herold, 383 U.S. 107 (Supreme Court) (equal protection in transfer from prison to civil commitment without jury trial)
Jackson v. Indiana, 406 U.S. 715 (Supreme Court) (limits on indefinite commitment when criminal process stalls)
Foucha v. Louisiana, 504 U.S. 71 (Supreme Court) (confinement must be based on present mental illness plus dangerousness)
Hubbart v. Knapp, 379 F.3d 773 (9th Cir.) (SVPs not similarly situated to other civil detainees)
Litmon v. Harris, 768 F.3d 1237 (9th Cir.) (post-Proposition 83 reaffirmation that SVPs differ from other civil detainees)
Seeboth v. Allenby, 789 F.3d 1099 (9th Cir.) (similar holding rejecting equal protection challenge)