On Point blog, page 2 of 2
SVP – Trial – Evidence: Prediction of Future Dangerousness of Juveniles
State v. Matthew A.B., 231 Wis.2d 688, 605 N.W.2d 598 (Ct. App. 1999)
For Matthew A.B.: Mary E. Waitrovich, SPD, Madison Appellate.
Issue/Holding: Prediction of future dangerousness may be made of a juvenile in a Ch. 980 proceeding.
The state’s experts assessed Matthew’s dangerousness by using the “Doren criteria,” which were developed through research involving adults. Moreover, Matthew adduced evidence “that juveniles have a lower propensity to reoffend in sexual violence situations.”
SVP Commitments – Based on Antisocial Personality Disorder
Reuben Adams v. Bartow, 330 F.3d 957 (7th Cir. 2003), denying habeas relief in State v. Adams, 223 Wis. 2d 60, 588 N.W.2d 336 (Ct. App. 1998)
For Adams: Samuel Arena (Foley & Lardner)
Issue: Whether the state court affirmance of Adams’ commitment unreasonably applied Kansas v. Hendricks, 521 U.S. 346 (1997) or Foucha v.