In Re Wright

A jury concluded that Robert Edward Wright was a sexually violent predator (SVP) within the meaning of the Sexually Violent Predators Act (the Act, Welf. & Inst. Code, § 6600 et seq.; all undesignated statutory references are to this code), and the court committed him to a state mental institution for a two-year term. As a procedural prerequisite to the commencement of this proceeding, the Director of the State Department of Mental Health (Director) was required to designate “two practicing psychiatrists or psychologists, or one practicing psychiatrist and one practicing psychologist,” to evaluate Wright. (§ 6601, subd. (d).) Because these evaluators did not agree on whether Wright was an SVP, the Director was required to arrange an examination by two “independent professionals” (§ 6601, subd. (e)), which are defined as including “licensed psychologists who have a doctoral degree in psychology.” (§ 6601, subd. (g).)

In this case, we conclude that the language of section 6601 unambiguously requires that licensed psychologists conducting a secondary evaluation under subdivision (g) have “a doctoral degree in psychology.” We also examine what it means to have “a doctoral…