United States v. Comstock, 627 F.3d 513 (4th Cir. 2010)
Nature of Case: On remand from United States Supreme Court in United States v. Comstock which reversed the Fourth Circuit’s determination that the Adam Walsh Act’s civil commitment provisions exceeded congressional authority, Fourth Circuit then had to resolve five identical challenges to civil commitment under the Due Process Clause.
Holding: Act’s requirement that government need only make proof that individuals met statutory criteria for civil commitment by clear and convincing evidentiary standard (as opposed to beyond a reasonable doubt) was constitutional, and did not offend Due Process Clause in light of prior precedent distinguishing civil commitment proceedings from criminal proceedings.