Henrickson v. State

Pending resolution of an appeal of his conviction for a 1990 kidnapping, Donald Henrickson was allowed to remain in the community under the supervision of his wife and other chaperones while participating in a sex offender treatment program. After his conviction was affirmed, he served a prison sentence. He was then civilly committed as a sexual predator on a petition filed one day before his release from prison. Henrickson argues that the petition was constitutionally defective because it did not allege a recent overt act manifesting his continued dangerousness. We hold that due process does…