Ambrose v. Roeckeman

Richard Ambrose (defendant) was charged with sexual abuse. The state sought civil commitment of Ambrose under the Illinois Sexually Dangerous Persons Act (SDPA). The SDPA allowed for the indefinite civil commitment of a person who had not yet been convicted of a sexual offense upon establishing that he was a sexually dangerous person. The state court found that Ambrose was a sexually dangerous person, and Ambrose was committed. The SDPA provided that a committed person could seek release on the basis that he had recovered and was no longer a sexually dangerous person. Ambrose filed a recovery application with the state court. At the hearing on the recovery application, Dr. Angeline Stanislaus testified as an expert witness. Stanislaus expressed an opinion about whether Ambrose was recovered. Stanislaus’s opinion was based on two prior allegations of sexual abuse made against Ambrose. The state-court judge admitted evidence of the prior abuse allegations. The prior abuse allegations were admitted to show the information considered by Stanislaus in the process of reaching her opinion. Thus, the prior abuse allegations were not admitted to prove the truth of the abuse. The state court ultimately denied Ambrose’s recovery application. Subsequently, Ambrose filed a petition for habeas corpus in federal court, asserting that his confinement was unlawful. The federal district court denied Ambrose’s habeas petition. Ambrose appealed.