In re the Detention of Galen Kendrick Shaffer

Summary

The Iowa Supreme Court considered whether Galen Kendrick Shaffer was “presently confined” under Iowa’s Sexually Violent Predator Act when the State filed a civil-commitment petition. Although Shaffer’s release date was later determined to have been improperly calculated under an ex post facto application of sentence-reduction statutes, he remained in custody pursuant to the Department of Corrections’ good-faith, unchallenged calculation at the time of filing. The court reversed the dismissal of the petition and remanded for further proceedings.

Holdings

1. A person is "presently confined" under Iowa Code section 229A.4(1) when, at the time the petition is filed, the person is in continuous state custody for a sexually violent offense pursuant to an unchallenged, good-faith application of the law, even if the legal basis for continued confinement is later found to be erroneous.
2. Statutory language in the Sexually Violent Predator Act must be interpreted consistently with the common law and other laws concerning similar subjects, with legislative intent determined through applicable interpretive rules.

Questions Presented

1. Whether Shaffer was "presently confined" under Iowa Code section 229A.4(1) when the State filed its petition for civil commitment, despite a later determination that the Department of Corrections had improperly calculated his earned-time reductions.

Disposition

reversed_and_remanded