Lawyer v. J.M., 2019 ND 125 (N.D. 2019).
Nature of Case: Appellant was civilly committed in North Dakota as a sexually dangerous individual who then subsequently petitioned for discharge. District court denied the petition, on the basis of opinions that he was still sexually dangerous, which were predicated on two violations of program rules that were non-sexual in nature. Appellant sought review.
Holding: North Dakota Supreme Court reversed on a clearly erroneous standard, finding that a nexus was required between Appellant’s mental disorder that necessitated his commitment and purported sexual dangerousness towards others.