West v. Macht.

• Position: CLASSIFICATION & SEPARATION - Brief Article

U.S. District Court

SEX OFFENDER

CIVIL COMMITMENT

West v. Macht, 235 F.Supp.2d 966 (E.D.Wis. 2002). Civilly-committed sex offenders brought a [section] 1983 action against employees of a state treatment facility. The district court held that security-related seclusion placements did not violate the offenders' substantive due process rights because they were rationally related to the purpose of maintaining institutional security and could not reasonably be characterized as punitive. But the court found that fact issues existed as to whether...