State v. Strauss

—A jury committed Gordon Michael Strauss to a secure facility after finding that he is a sexually violent predator. Strauss appeals, arguing that the trial court failed to hold a Frye1 hearing on certain actuarial instruments used by experts to assess his risk of recidivism. He also contends that the court should have considered less restrictive alternatives short of total confinement. Finally, he maintains that the court erred by not instructing the jury to make a specific finding that he is unable to control his behavior. We affirm because the relevant scientific community generally accepts…