Ladd R. Erickson, State's Attorney, Petitioner and Appellee v. Jay Chandler Hicks, Respondent and Appellant (2025)

Supreme Court of North Dakota.

In the INTEREST OF Jay Chandler HICKS Ladd R. Erickson, State's Attorney, Petitioner and Appellee v. Jay Chandler Hicks, Respondent and Appellant

No. 20250025

Decided: June 18, 2025

Ladd R. Erickson, State's Attorney, Washburn, ND, petitioner and appellee; on brief. Tyler J. Morrow, Grand Forks, ND, for respondent and appellant; on brief.

[¶1] Jay Hicks appeals from a district court order denying his petition for discharge from commitment as a sexually dangerous individual. He argues the court's order is not supported by clear and convincing evidence that he has serious difficulty controlling his behavior. “We review civil commitments of sexually dangerous individuals under a modified clearly erroneous standard of review.” In re G.L.D., 2023 ND 99, ¶ 6, 991 N.W.2d 62. We will affirm a district court's order unless it is induced by an erroneous view of the law or we are firmly convinced the order is not supported by clear and convincing evidence. Id. We conclude the court's order is supported by clear and convincing evidence that Hicks has serious difficulty controlling his behavior and summarily affirm under N.D.R.App.P. 35.1(a)(2).

Per Curiam.

[¶2] Jon J. Jensen, C.J. Daniel J. Crothers Lisa Fair McEvers Jerod E. Tufte Douglas A. Bahr

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