Billy Redding v. Stephanie Clendenin, et al.

Summary

The United States District Court for the Eastern District of California partially adopted the magistrate judge’s findings and recommendations in Billy Redding’s civil rights action concerning his civil detention as a sexually violent predator. The court dismissed with leave to amend Redding’s Fourteenth Amendment claim alleging denial of access to mental health treatment through temporary community “day passes.” The case will otherwise proceed on his claim that the conditions of confinement are punitive or excessively restrictive.

Holdings

1. Redding alleged sufficient facts to support a plausible Fourteenth Amendment claim that the conditions of his civil confinement were punitive or excessively restrictive compared with those imposed on prison inmates.
2. The treatment claim was not viable as pleaded and was dismissed with leave to amend.
3. The facial challenge failed because the complaint did not establish that the treatment policy lacked any constitutional application.
4. The state court's conditional-release judgment would have preclusive effect against Redding's as-applied claim because the state court necessarily and finally determined that he remained dangerous even under supervision and treatment in the community.

Questions Presented

1. Whether Redding plausibly alleged that the conditions of his civil detention were punitive or excessively restrictive in violation of the Fourteenth Amendment.
2. Whether Redding plausibly alleged that denial of temporary community day passes for treatment deprived him of a realistic opportunity to be cured or improve his mental condition.
3. Whether the treatment claim failed because the challenged treatment policy could have constitutional applications and because the state court's conditional-release determination had preclusive effect.

Disposition

other