U.S. v. Comstock (US 2010)

United States v. Comstock, 560 U.S. 126 (2010)

Nature of Case:Five defendants convicted of sex crimes in federal court were petitioned for civil commitment under the Adam Walsh Act of 2006. In appealing their various commitments, they alleged that the constitution required proof beyond a reasonable doubt that they met the statutory standards, and also that the civil commitment aspects of the AWA exceeded Congress’ authority under the Necessary and Proper Clause. District Court dismissed, state appealed, and appellate court affirmed dismissals on N&P grounds. State petitioned for cert, which was granted on N&P grounds.

Holding:  Limiting review to the question of whether federal statute authorizing civil commitment of federal inmates was constitutional under the Necessary & Proper Clause, the Court in a 7-2 decision upheld its legality. The statute was a proper exercise of federal authority, did not violate the Tenth Amendment, and did not confer onto Congress a general police power.