United States v. Walter Wooden
2012 U.S. App. LEXIS 18747
| 4th Cir. | 2012Background
- The government sought civil commitment of Wooden as a sexually dangerous federal inmate under 18 U.S.C. § 4248(a) after his scheduled release.
- The district court dismissed the petition, finding no pedophilia and no serious-difficulty refraining from reoffending, and ordered Wooden released.
- The government appealed, and the Fourth Circuit reversed, remanding for reconsideration on the existing record.
- Evidence included Wooden’s past offenses, treatment history, and various expert opinions on pedophilia and risk of reoffense.
- Two government experts diagnosed pedophilia with high recidivism risk; Wooden’s sole defense expert concluded no current pedophilia and no volitional impairment.
- The district court discounted confounding evidence (e.g., Wooden’s thoughts, fantasies, high-risk behaviors, and dream-like admissions) and focused on Campbell’s opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wooden still suffers from pedophilia at the time of the hearing | Government: Pedophilia persisted, supported by multiple indicators and test results. | Wooden: Campbell’s view is correct; pedophilia had abated with age and treatment, and 2005 incident evidence was unreliable or non-existent. | Pedophilia not sustained by the district court; district court erred; pedophilia found to persist. |
| Whether Wooden would have serious difficulty refraining from re-offense if released | Government: Expert evidence shows high or very high risk of recidivism and persistent pedophilia. | Campbell’s view of no volitional impairment due to lack of impulsivity controls risk. | Reversal: the district court’s finding of no serious difficulty refraining was clearly erroneous. |
| Whether the government needed to prove ‘dangerousness’ separately or as part of the ‘serious difficulty’ standard | Government: Dangerousness is encompassed by the serious-difficulty criterion under the Act. | District court required separate, explicit proof of dangerousness beyond the statute’s standard. | The Act’s standard satisfies dangerousness without requiring a separate threshold; remanded for reconsideration on the existing record. |
| Whether the district court properly considered and weighed conflicting expert and testimonial evidence | Government: The district court erred by crediting Campbell over others and ignoring contradictory evidence. | Wooden: The court’s credibility determinations were proper and Campbell’s opinion deserved deference. | District court’s factual findings were clearly erroneous; we reverse and remand. |
Key Cases Cited
- Kansas v. Crane, 534 U.S. 407 (2002) (dangerousness and lack of control in civil commitment)
- United States v. Hall, 664 F.3d 456 (4th Cir. 2012) (serious-difficulty prong and risk assessment)
- United States v. Joshua, 607 F.3d 379 (4th Cir. 2010) (custody language and civil-commitment framework)
- Anderson v. Bessemer City, 470 U.S. 564 (1985) (clear-error review and credibility determinations)
- In re United States Gypsum Co., 333 U.S. 364 (1948) (reciprocal standard for clearly erroneous findings)
- Addington v. Texas, 441 U.S. 418 (1979) (expert testimony in mental-illness determinations)
- Mercy Hosp. v. City of Bedford, 720 F.2d 361 (4th Cir. 1983) (evidence weighing in trial rulings)
- Martinez-Melgar, 591 F.3d 733 (4th Cir. 2010) (clear-error standard and weight of evidence in recidivism analysis)
- Doe v. Menefee, 391 F.3d 147 (2d Cir. 2004) (weighing conflicting evidence and cognitive testimony)
- Taylor v. Maddox, 366 F.3d 992 (9th Cir. 2004) (reasoned discussion of weighing conflicting record evidence)
- United States v. Hunt, 643 F. Supp. 2d 161 (D. Mass. 2009) (recidivism rates not dispositive; focus on self-control)