Taylor v. San Diego Cty.

Laws that permit the state to indefinitely commit sexually violent predators to a mental health facility do not violate the Equal Protection Clause, nor is it a violation of the Due Process Clause to place the burden of proof on the committed individual to prove the individual is no longer dangerous.

Ronald Taylor was convicted of violently raping three separate victims. In 2006, revisions to California’s Sexually Violent Predator Act (“SVPA”) “replaced the two-year civil commitment period with an indefinite term of commitment” for sexually violent predators. Following the revisions, Taylor was committed to the California Department of Mental Health indefinitely for involuntary treatment as a sexually violent predator. On appeal, Taylor argued that the revisions to the civil commitment statute violated state and federal due process by placing the burden of proof on him to establish that he was no longer a sexually violent predator. Further, Taylor argued that his state and federal right to equal protection was violated because as a sexually violent predator, he was being treated differently than other civilly committed offenders. ­­­­The district court denied Taylor’s habeas petition. After the California Supreme Court declined discretionary review, Taylor filed a habeas petition in federal court challenging his commitment. The magistrate judge determined that the state court reasonably applied federal law in denying Taylor’s claims. On appeal, the Ninth Circuit reviewed Taylor’s arguments and denied petition. On Taylor’s Equal Protection claim, the panel noted that sexually violent predators are not similarly situated to other civilly committed offenders given the “detailed statutory schemes distinguishing the two classifications” and the “expressed legislative policy [] to protect the public from . . . sexually violent predators.” The panel also noted that the lower court reasonably applied federal law to Taylor’s Due Process claim, namely in that there is an absence of clearly established federal law prohibiting California from assigning Taylor the burden of proof. The panel, therefore, affirmed the district court’s denial of Taylor’s habeas corpus petition. AFFIRMED.