IN RE DETENTION OF BROWN

No. 62383-4-I.

225 P.3d 1028 (2010)

154 Wash.App. 116

In the Matter of the DETENTION OF Harold G. BROWN.

Court of Appeals of Washington, Division 1.

January 11, 2010.


Attorney(s) appearing for the Case

Jennifer M. Winkler, Nielsen Broman & Koch, PLLC, Seattle, WA, for Appellant.

Kristie Barham, Office of the Attorney General, Seattle, WA, for Respondent.


LEACH, J.

¶ 1 Harold Glen Brown appeals his commitment as a sexually violent predator (SVP) under chapter 71.09 RCW. He contends that procedures used by the trial court to determine whether the crime for which he was incarcerated constituted a recent overt act violated his due process rights. We hold no constitutional error occurred and affirm Brown's civil commitment.

Background

¶ 2 Brown has a history of sex offenses, including convictions...

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