People v. Coan

Citations: 724 N.E.2d 1049; 311 Ill. App. 3d 296; 244 Ill. Dec. 161; 2000 Ill. App. LEXIS 82Docket: 2-98-1207

Court: Appellate Court of Illinois; February 10, 2000; Illinois; State Appellate Court

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Wesley A. Coan appeals the circuit court's order committing him to the Illinois Department of Corrections as a sexually dangerous person under the Sexually Dangerous Persons Act. He argues that the Act violates his constitutional rights to due process and equal protection by not allowing consideration for less restrictive treatment options and lacking a maximum commitment period, unlike the provisions for individuals found not guilty by reason of insanity. Coan has a history of sexual offenses, including aggravated incest and sexual assault, and was evaluated by two court-appointed psychiatrists who confirmed his mental disorder and risk of reoffending. The court found him a sexually dangerous person and appointed the Director of the Department of Corrections as his guardian. The appellate court noted that Coan's arguments against the Act had been previously rejected in two cases, establishing that individuals committed under the Act and those under the Sexually Violent Persons Commitment Act are not similarly situated.

The court found that although there are procedural differences between the commitment processes under two relevant acts, defendants committed under the Act are not treated significantly more harshly than those classified as sexually violent persons. The Act offers the Department of Corrections (DOC) various treatment alternatives, even though it does not mandate treatment in the least restrictive environment. The court upheld that both statutes are designed to balance treatment provision and public safety against sexual violence.

The defendant sought to challenge the Act by arguing it violates equal protection rights, as it allows for indefinite commitment without a maximum term, unlike individuals found not guilty by reason of insanity. The defendant asserted that both categories are similarly situated—both have committed offenses but are not criminally responsible due to mental conditions. The State acknowledged the issue was not addressed in previous cases but maintained similar principles apply.

Under the rational basis test, a statute that lacks a "suspect classification" must only serve a legitimate governmental interest. The Act, which allows the Director of Corrections to act as guardian for sexually dangerous individuals, contrasts with the commitment of those found not guilty by reason of insanity, who are limited to a maximum term based on potential sentencing. The court noted that while the defendant is similarly situated to those found not guilty by reason of insanity, there exists a rational basis for their differential treatment.

A defendant found not guilty by reason of insanity must have been insane at the time of their crimes, which are typically committed within a short timeframe. In contrast, a sexually dangerous person, like the defendant, must exhibit a propensity for sex offenses and possess a mental disorder lasting at least one year, as defined by 725 ILCS 205/1.01 (West 1996). The ongoing nature of the mental disorder justifies different treatment between the two categories. Although a defendant acquitted on the grounds of insanity cannot be committed beyond their maximum potential sentence, they can be subject to civil commitment under the Mental Health Code indefinitely. Conversely, a sexually dangerous person can petition for release at any time, initiating a process that includes a socio-psychiatric evaluation and a court hearing to determine their status. The case of McDougle clarifies that such individuals have the right to judicial review regarding their care and treatment. Consequently, both categories face potential indefinite commitment, but with safeguards enabling their release upon recovery. The court upheld the constitutionality of the Act, noting the defendant did not contest the evidence establishing his status as a sexually dangerous person or the commitment order, leading to the affirmation of the circuit court's judgment.