United States v. Comstock
Issues
May Congress authorize the civil commitment of a “sexually dangerous” person even after that person has completed his or her prison sentence?
Petitioner, the United States, argues that 18 U.S.C § 4248, which authorizes the civil commitment of “sexually dangerous” persons, is a constitutional exercise of Congressional power. Respondents, Graydon Earl Comstock Jr., et al. (“Comstock”), counter that civil commitment of an individual after the completion of a federal prison sentence exceeds Congressional power, because it (1) encroaches on states’ authority and (2) is neither necessary nor proper to operating a valid federal regulation. The Fourth Circuit rejected the United States’ argument that § 4248 is necessary and proper to its ability to maintain the federal penal system. The Supreme Court must now decide (1) whether § 4248 is incidental to Congress’ Article I powers and (2) whether civil commitment of individuals labeled “sexually dangerous” and already in federal custody or incompetent to stand trial is an encroachment on state power.
Questions as Framed for the Court by the Parties
Whether Congress had the constitutional authority to enact 18 U.S.C. § 4248, which authorizes court-ordered civil commitment by the federal government of (1) "sexually dangerous" persons who are already in the custody of the Bureau of Prisons, but who are coming to the end of their federal prison sentences, and (2) "sexually dangerous" persons who are in the custody of the Attorney General because they have been found mentally incompetent to stand trial.
This consolidated action addresses whether the U.S. Constitution grants Congress the authority to enact 18 U.S.C. § 4248. See U.S. v. Comstock, 551 F.3d 274, 275–76 (4th Cir.