Schmidt v. McCulloch

Federal 7th Circuit Court
Civil Court
Due Process
Citation
Case Number: 
No. 14-3651
Decision Date: 
May 26, 2016
Federal District: 
W.D. Wisc.
Holding: 
Affirmed

Dist. Ct. did not err in denying plaintiff’s habeas petition challenging his civil commitment as sexually dangerous person, even though plaintiff argued that his due process rights were violated because govt. introduced into evidence his detailed, first-person accounts of his prior sex crimes. While Dist. Ct.’s dismissal was based on its finding that plaintiff had failed to exhaust his remedies in state judicial system, Ct. of Appeals found that plaintiff had satisfied exception to exhaustion requirement, where plaintiff alleged that there was no basis for his civil commitment at time it occurred. However, Ct. found no error in admission of said first-person accounts, where said accounts: (1) illustrated plaintiff’s psychiatric traits that allowed jury to evaluate whether his predisposition to commit sexual offenses had changed in 20 years; and (2) aided jury in resolution of necessarily uncertain issue as to whether plaintiff would re-offend even with sex-offender treatment.