Mental Abnormality Legal Definition
The United States Supreme Court held in Kansas v. Hendricks (1997) 521 U.S. 346, that the definition of "mental abnormality" in the Kansas Sexually Violent Predator Act satisfied substantive due process requirements. (Id. at pp. 356-360.)
The court reasoned that the Kansas statutory scheme "requires a finding of future dangerousness, and then links that finding to the existence of a 'mental abnormality' or 'personality disorder' that makes it difficult, if not impossible, for the person to control his dangerous behavior. " (Id. at p. 358.)
The court concluded that the requirement in the Kansas statutory scheme "of a 'mental abnormality' or 'personality disorder' is consistent with the requirements of . . . other statutes that it has upheld in that it narrows the class of persons eligible for confinement to those who are unable to control their dangerousness." (Id. at p. 358.)
In Kansas v. Crane (2002) 534 U.S. 407 (Crane), the United States Supreme Court again considered the Kansas Sexually Violent Predator Act and explained that Hendricks, supra, 521 U.S. 346, did not set forth a "requirement of total or complete lack of control." (Crane, supra, 534 U.S. at p. 411.)
The Crane court reasoned: "an absolutist approach is unworkable. Moreover, most severely ill people -- even those commonly termed 'psychopaths' -- retain some ability to control their behavior. Insistence upon absolute lack of control would risk barring the civil commitment of highly dangerous persons suffering severe mental abnormalities." (Id. at pp. 411-412.)
Among other citations, the Crane court quoted psychological authority stating that "'"the line between an irresistible impulse and an impulse not resisted is probably no sharper than that between twilight and dusk."'" (Crane, supra, 534 U.S. at p. 412.)
The Crane court emphasized, however, that the federal constitution did not permit commitment under the Kansas statute "without any lack-of-control determination" being made. (Crane, supra, 534 U.S. at p. 412.) As to the requisite amount of lack of control, the Crane court explained that "in cases where lack of control is at issue, 'inability to control behavior' will not be demonstrable with mathematical precision. It is enough to say that there must be proof of serious difficulty in controlling behavior. And this, when viewed in light of such features of the case as the nature of the psychiatric diagnosis, and the severity of the mental abnormality itself, must be sufficient to distinguish the dangerous sexual offender whose serious mental illness, abnormality, or disorder subjects him to civil commitment from the dangerous but typical recidivist convicted in an ordinary criminal case. " (Id. at p. 413.)
In People v. Williams (2003) 31 Cal.4th 757, the California Supreme Court addressed whether a separate jury instruction regarding the issue of control was constitutionally required after Crane, supra, 534 U.S. 407, in order to commit an individual under California's SVPA. At trial, the defendant had sought, but was refused, an instruction that "'the diagnosed mental disorder must render the person unable to control his dangerous behavior.'" (Williams, supra, 31 Cal.4th at p. 763.)
The jury ultimately found the defendant to be a sexually violent predator.
On appeal, the defendant asserted that his commitment was invalid because the language of the SVPA did not include "the federal constitutional requirement of proof of a mental disorder that causes 'serious difficulty in controlling behavior' (Crane, supra, 534 U.S. at p. 413) and the jury was not specifically instructed on the need to find such impairment of control." (Williams, supra, 31 Cal.4th at p. 764.)
The California Supreme Court disagreed.
The court explained that "by its express terms, the SVPA limits persons eligible for commitment to those few who have already been convicted of violent sexual offenses . . . ( 6600, subd. (a)(1)), and who have 'diagnosed mental disorders' (ibid.) 'affecting the emotional or volitional capacity' (id., subd. (c)) that 'predispose them to the commission of criminal sexual acts in a degree constituting them menaces to the health and safety of others' (ibid.), such that they are 'likely to engage in sexually violent criminal behavior' (id., subd. (a)(1)). This language inherently encompasses and conveys to a fact finder the requirement of a mental disorder that causes serious difficulty in controlling one's criminal sexual behavior. The SVPA's plain words thus suffice 'to distinguish the dangerous sexual offender whose serious mental illness, abnormality, or disorder subjects him to civil commitment from the dangerous but typical recidivist convicted in an ordinary criminal case.' (Kansas v. Crane, supra, 534 U.S. 407, 413.)" (Williams, supra, 31 Cal.4th at pp. 759-760.)
The court concluded that because "a commitment rendered under the plain language of the SVPA necessarily encompasses a determination of serious difficulty in controlling one's criminal sexual violence, as required by Kansas v. Crane, supra, 534 U.S. 407, . . . separate instructions or findings on that issue are not constitutionally required, and no error arose from the trial court's failure to give such instructions in defendant's trial." (Williams, supra, 31 Cal.4th at p. 777.)