United States v. Blake Charboneau
914 F.3d 906
| 4th Cir. | 2019Background
- Blake Charboneau, with a long history of alcohol-related offenses including multiple sexual assaults (one against his daughter), was serving a federal sentence when the Government sought civil commitment under the Adam Walsh Act as a "sexually dangerous person."
- The Government bears burden to prove by clear and convincing evidence three elements: prior sexually violent conduct, a current "serious mental illness, abnormality, or disorder," and that, as a result, the person would have serious difficulty refraining from sexually violent conduct if released.
- At the commitment hearing, Government experts diagnosed Charboneau with alcohol use disorder; one expert (Dr. Zinik) also diagnosed a mixed personality disorder (schizotypal/schizoid features) and opined that the disorders together create high risk of reoffense.
- Charboneau’s expert (Dr. Plaud) agreed on prior conduct but argued alcohol use disorder alone does not satisfy the mental-illness element and that relapse-based speculation cannot establish serious difficulty refraining from reoffense.
- The district court credited Dr. Zinik’s opinions, found the Government met its burden by clear and convincing evidence on all elements, and committed Charboneau to the Attorney General. Charboneau appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a paraphilic disorder is required to satisfy the Act’s "serious mental illness, abnormality, or disorder" element | Charboneau: statute requires a paraphilic disorder to meet the element | Government: statute does not require any specific diagnosis; other disorders (e.g., alcohol use disorder) may satisfy it | Court: No; statute does not require a paraphilic disorder; government can rely on other serious disorders but must show causal link to dangerousness |
| Whether the district court clearly erred in finding Charboneau had a mixed personality disorder (plus alcohol use disorder) satisfying the mental-illness element | Charboneau: only Dr. Zinik reached that diagnosis; it was against the weight of evidence | Government: district court credited Dr. Zinik after reviewing records and expert testimony; credibility determinations are for the trial court | Court: Affirmed; appellate court defers to district court crediting Dr. Zinik’s opinion |
| Whether there was adequate causal connection (serious difficulty element) between diagnosis(es) and risk of future sexually violent conduct | Charboneau: evidence insufficient; reliance on likely alcohol relapse is speculative; expert evidence favors non-commitment | Government: experts tied alcohol use and personality disorder to past offenses and risk assessments showing high reoffense risk | Court: Affirmed; district court reasonably found a causal connection and credited persuasive expert risk analysis |
| Whether the court failed to give proper weight to Charboneau’s ~15 years of good conduct while incarcerated | Charboneau: long-term institutional compliance shows low risk, requiring reversal under Antone | Government: district court considered and weighed incarceration behavior against historical community relapse and other risk factors | Court: Affirmed; district court considered good conduct but reasonably concluded community risk and other factors outweighed it |
Key Cases Cited
- United States v. Caporale, 701 F.3d 128 (4th Cir.) (statutory phrase "serious mental illness, abnormality, or disorder" is not limited to DSM-listed disorders)
- United States v. Antone, 742 F.3d 151 (4th Cir.) (district court must adequately consider recent good institutional conduct when evaluating commitment)
- Anderson v. Bessemer City, 470 U.S. 564 (U.S. 1985) (standard for reviewing factual findings for clear error)
- Carmell v. Texas, 529 U.S. 513 (U.S. 2000) (quality, not quantity, of testimony controls credibility assessments)
- United States v. Comstock, 560 U.S. 126 (U.S. 2010) (constitutionality of federal civil commitment under the Adam Walsh framework)
- United States v. Wooden, 693 F.3d 440 (4th Cir.) (appellate deference to district court factfinding in Adam Walsh cases)
- United States v. Bell, 884 F.3d 500 (4th Cir.) (gaps in temporal pattern of offenses do not preclude finding serious difficulty refraining from future sexually violent behavior)