Allen v. Illinois

478 U.S. 364, 106 S. Ct. 2988, 92 L. Ed. 2d 296 (1986)

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Allen v. Illinois

United States Supreme Court
478 U.S. 364, 106 S. Ct. 2988, 92 L. Ed. 2d 296 (1986)

Facts

Illinois (defendant) enacted a sex-offender statute, which targeted sexually dangerous individuals. The act authorized state-initiated commitment of those individuals upon proof that they had committed, or attempted to commit, at least one sexual assault. The act expressly stated that its purpose was to provide psychiatric care and treatment for those subject to the act in a mental-healthcare facility. The act stated that proceedings to determine sexual dangerousness were civil in nature, not criminal or punitive. However, the act imposed procedural safeguards like those imposed in criminal trials, including requiring the state to prove sexual dangerousness beyond a reasonable doubt. Those committed under the act were housed in a state maximum-security psychiatric facility that also housed mentally ill criminals. Those committed could petition for discharge once they were able to prove that they were no longer dangerous. Allen (plaintiff) challenged the act’s constitutionality up to the state’s highest court, arguing that the act’s requirement that he disclose sexual assaults he committed violated his privilege against self-incrimination. The Illinois Supreme Court determined that although the act provided strict procedural safeguards like those provided in criminal trials, sexual-dangerousness proceedings were civil in nature and did not implicate the Fifth Amendment. Allen requested certiorari.

Rule of Law

Issue

Holding and Reasoning (Rehnquist, J.)

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