U.S. First Circuit - The FindLaw 1st Circuit Court of Appeals News and Information Blog

Young v. Murphy, 09-1685

Young v. Murphy, 09-1685, concerned a challenge to the district court's denial of defendant's petition for habeas relief, from his civil commitment to the Massachusetts Treatment Center pursuant to Chapter 123A of the Massachusetts General Laws, after a state court jury found that he was a sexually dangerous person.

In affirming, the court held that the district court did not unreasonably apply Supreme Court precedent when it refused to credit defendant's categorical claim that a diagnosis of antisocial personality disorder (ADP) can never serve as a sufficient basis for civil commitment because the disorder does not affect volition and is so prevalent among criminal offenders that it cannot be used to distinguish ordinary recidivists from the dangerously mentally ill.  The court also held that the Massachusetts Court of Appeals did not unreasonably apply Supreme Court precedent in rejecting defendant's argument that the record does not establish that APD causes him serious difficulty in controlling his sexual impulses.

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