Jackson v. California Department of Mental Health

MEMORANDUM **

Vashon Tyrone Jackson seeks federal habeas relief, claiming that his commitment under California’s Sexually Violent Predator Act (SVPA) violates federal due process. Jackson was committed in 1996 after qualifying for the SVPA by virtue of three previous convictions for unlawful sexual intercourse with a minor and forcible rape. Jackson argues California unlawfully held him in custody for SVPA proceedings after he had successfully completed a 6-month sentence for a parole violation. As a result, he maintains his continuing custody under the SVPA violates his Fourteenth Amendment right to due process.

Because California’s application of state law was not contrary to or an unreasonable application of United States Supreme Court due process law, we DENY his ha-beas corpus petition.

I. Background

The parties are familiar with the facts and procedural background so we need not recount all of the details here.

In sum, California’s SVPA allows the state to confíne particularly dangerous individuals who have been convicted of multiple sexual offenses. Cal. Welf. & Inst. Code § 6600 et seq. The SVPA defines a “sexually violent predator” (SVP) as “a person who has been…