Ward v. State

The state sought involuntary commitment of the defendant as a sexually violent predator under the Jimmy Ryce Act. The Act, enacted in 1999, provided for civil commitment procedures for “all persons currently in custody who have been convicted of a sexually violent offense . . . as well as to all persons convicted of a sexually violent offense in the future.” The defendant had been convicted of rape in 1969 and 1976. In 2004, he was sentenced to prison for burglary charges. He argued that the Act did not authorize his commitment since he had not been convicted of any sexually violent offense since the effective date of the Act. The trial court disagreed and the Florida Supreme Court affirmed, finding that the “current confinement period need not be for a sexual offense as long as the individual has been convicted of a sexually violent offense sometime in the past.”