Matter of Detention of Pugh

Robbie Pugh challenges his detention under the involuntary commitment statutes, contending that the State is using the commitment process as additional punishment for two statutory rape convictions for which he served a prison term. He asserts that his commitment is inharmonious with legislative intent and that his prior convictions provide insufficient evidence of a recent overt act to support a finding that he presents a likelihood of serious harm to others as required under RCW 71.05.320(2)(b). We affirm.

In 1986, Pugh pleaded guilty to two counts of first degree statutory rape involving 8-…