Kansas v. Crane
United States Supreme Court
534 U.S. 407 (2002)
Crane (defendant), a previously convicted sex offender diagnosed with exhibitionism and antisocial personality disorder, was ordered civilly committed after a jury trial under Kansas's sexual-predator commitment scheme. The Kansas Supreme Court reversed, reading the Court's earlier decision in Kansas v. Hendricks as requiring a specific finding that Crane was completely unable to control his dangerous behavior - a finding the trial court hadn't made. Kansas appealed, arguing the state court misread Hendricks as demanding total lack of control rather than something less absolute.
Whether the state must prove a dangerous individual is completely unable to control his behavior before he may be civilly committed.