Taylor v. San Diego County, No. 12-55030 [September 9, 2015]
Taylor was committed indefinitely for involuntary treatment as a sexually violent predator under California law. He raised two claims: 1) that California’s Sexually Violent Predator Act violates the Equal Protection Clause because it contains release procedures that are more onerous than those placed on other civilly committed detainees; and 2) the Act violates the federal Due Process Clause because it contains a burden-shifting scheme requiring the detainee to prove that he is no longer a sexually violent predator in order to terminate his commitment. The Court affirmed the state court denial of relief as not contrary to or an unreasonable application of controlling Supreme Court precedent. On the equal protection claim the Court found that, contrary to Taylor’s argument, LPS Act detainees are not similarly situated persons as they are not “similar in the respects pertinent to the State’s policy.” On the due process claim the court found that the applicable clearly establish federal law, Jones v. United States, 463 US 354 (1983), was reasonably relied on by the California Court of Appeal and that the other cases cited by Taylor were not clearly established federal law on the issue of re-commitment proceedings.