United States v. Walter Wooden
887 F.3d 591
4th Cir.2018Background
- Walter Wooden, a federal inmate with limited intellectual capacity, was civilly committed under the Adam Walsh Act after the government sought commitment as he neared release; he was initially committed in 2014 after earlier proceedings.
- Wooden has multiple historical convictions for sexual offenses against minors (1970s–1980s); incidents in 2002–2005 included admissions on polygraph and a reported laundry-room episode.
- Experts at earlier proceedings diagnosed pedophilia and recommended commitment; the district court initially denied commitment, appellate remanded for errors, and district court later certified Wooden as sexually dangerous; this Court remanded again for reconsideration.
- In 2016 Wooden sought discharge under 18 U.S.C. § 4247(h). New experts (Drs. Winsmann and Plaud) diagnosed Intellectual Developmental Disorder (IDD), opined IDD better explained past offenses, and concluded Wooden no longer exhibited current pedophilic arousal or serious volitional impairment.
- Government experts (Drs. Malinek and Ross) maintained pedophilic disorder and ongoing dangerousness, relying on historical behavior and actuarial risk tools; district court credited Winsmann/Plaud, found no qualifying serious mental illness under § 4247(a)(6), and ordered unconditional release.
- Fourth Circuit affirmed, applying clear-error review to the district court’s factual findings, concluding the court’s resolution favoring the IDD diagnosis and crediting Wooden’s lack of current pedophilic urges was plausible.
Issues
| Issue | Plaintiff's Argument (Government) | Defendant's Argument (Wooden) | Held |
|---|---|---|---|
| Whether Wooden suffers from pedophilic disorder (qualifying serious mental illness) | Government: historical crimes, admissions, and actuarial scores show pedophilic disorder persists | Wooden: IDD explains past conduct; no current recurrent/intense sexual arousal to children | Court: Held Wooden does not suffer from pedophilic disorder; IDD diagnosis credible and plausible |
| Whether Wooden currently has a mental-condition-related volitional impairment (serious difficulty refraining) | Government: historical recidivism and expert opinions indicate ongoing high risk and impaired control | Wooden: Experts and behavioral evidence show improved self-control, no current urges, and protective factors (age, infirmity, release plan) | Court: Did not reach volitional issue because no qualifying disorder found; district court’s volitional findings credited in any event |
| Whether district court clearly erred in crediting defense experts over government experts | Government: Defense experts unpersuasive; court ignored contradictory evidence and relied on inmate testimony | Wooden: Defense experts performed direct testing/interviews; government experts relied on records/actuarials without interviewing Wooden | Court: Credibility choice permissible; Winsmann/Plaud coherent, tested, and their views not implausible under clear-error review |
| Whether conditional release could be imposed | Government: If not unconditionally safe, court should impose conditions on release | Wooden: Discharge petition triggers unconditional discharge provisions unless treatment is required to prevent dangerousness | Court: Act requires unconditional discharge when detainee is not sexually dangerous; conditions not authorized here |
Key Cases Cited
- United States v. Wooden, 693 F.3d 440 (4th Cir. 2012) (earlier Fourth Circuit opinion addressing errors in initial district findings)
- Anderson v. City of Bessemer City, 470 U.S. 564 (U.S. 1985) (standard for reviewing factual findings for clear error and deference to factfinder’s credibility choices)
- United States v. Caporale, 701 F.3d 128 (4th Cir. 2012) (clarifying that commitment requires both qualifying mental disorder and volitional impairment)
- United States v. Hall, 664 F.3d 456 (4th Cir. 2012) (review of sexually dangerous determinations and clear-error standard)
- United States v. Antone, 742 F.3d 151 (4th Cir. 2014) (criticizing failure to account for post-commitment personal growth in commitment analyses)
- United States v. Perez, 752 F.3d 398 (4th Cir. 2014) (expert evaluation of denials of pedophilic arousal in Adam Walsh detainee cases)
- United States v. Maclaren, 866 F.3d 212 (4th Cir. 2017) (reference to DSM-V in analogous context)