In re Det. of Anderson (Majority and Dissent)
Annotate this CaseIn 1988, when petitioner John Anderson was 17 years old, he pled guilty in juvenile court to statutory rape in the first degree. The victim was two and a half years old. Anderson was sentenced to 100 weeks in a juvenile rehabilitation facility. When Anderson's juvenile sentence was about to expire in 1990, the State petitioned to have him involuntarily committed and he was transferred to Western State Hospital (WSH) for an evaluation. Before the evaluation period ended, Anderson voluntarily sought civil commitment. In February 2000, Anderson announced his intention to end his voluntary commitment and the State petitioned to have him involuntarily committed as a sexually violent predator (SVP) pursuant to chapter 71.09 RCW. Anderson was transferred to the Special Commitment Center (SCC) during the pendency of the State's petition in March 2001. In 2004, after a bench trial, the trial court found Anderson was an SVP. The Court of Appeals reversed, holding that the trial court abused its discretion by failing to appoint Anderson's requested expert witness. The Supreme Court agreed. On remand, Anderson moved to dismiss, contending that his juvenile adjudication was not a conviction, and thus he could not be subject to an SVP petition under RCW 71.09.030(1)(e). He also contended that his sexual contacts with other patients at WSH were not recent overt acts as a matter of law. The trial court denied Anderson's motion to dismiss, and Anderson was retried by a jury. The jury concluded that Anderson was an SVP, and the trial court entered an order committing him to the SCC. The Court of Appeals affirmed in an unpublished decision. Anderson petitioned the Supreme Court to ask that his civil commitment under chapter 71.09 RCW be reversed. Specifically, he asked whether juvenile adjudication for a sexually violent offense was a predicate "convict[ion]" under RCW 71.09.030(1)(e). The Supreme Court held that it was, and affirmed his civil commitment.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.