Willis v. Palmer (N.D. Iowa 2018)

Willis v. Palmer, No. 12- CV–4086 (N.D. Iowa 2018)

Nature of Case: Plaintiffs, all civilly committed individuals housed within Iowa’s Civil Commitment Unit for Sex Offenders, brought civil rights challenge arguing that their continued detention was unconstitutional on a number of grounds. Subsequent to prior dismissal, remaining claims where whether the treatment program met the constitutional “shock the conscience” standard, whether the application of the civil commitment statutes were punitive, and whether the procedures at the civil commitment facility were the least restrictive alternative.

Holding:  Held: District Court, largely in light of the 8th Circuit’s Decision in Karsjens v. Piper, dismissed the litigation as a matter of law.