Division I: Insane Beaver's Revoked Release A-OK
Beaver got out of a residential burglary charge…sort of…through an insanity plea. He was allowed a conditional release a few years later, which he violated. They revoked his release. However, he was never released completely from commitment. Thus, the State didn’t have to prove that he continued to be a threat in order to revoke his release:
Beaver's recommitment upon the revocation of conditional release is supported by adequate findings of mental illness and dangerousness. At the revocation hearing here, the trial court determined that Beaver violated release conditions and presented a danger to the community. And Beaver's insanity, as asserted by Beaver in his criminal proceeding and established by the trial court's original findings, was presumed to continue to exist. Given these findings, the State's action in recommitting Beaver was not arbitrary and his confinement is consistent with substantive due process demands.
Rather, Beaver had the same procedural safeguards as any one else committed for insanity, which is adequate for due process.