In the Matter of Snow

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Daryl Snow appealed his commitment as a sexually violent predator under the Sexually Violent Predator Act. He argued his diagnosis of Other Specified Personality Disorder was legally insufficient to meet the constitutional and statutory requirements for commitment under the Act, and thus the trial court erred when it denied his motions for a directed verdict and judgment notwithstanding the verdict (JNOV). The court of appeals affirmed his commitment in an unpublished opinion. Finding no reversible error, the South Carolina Supreme Court affirmed the court of appeals. The Supreme Court determined the diagnosis was legally sufficient to satisfy the second element of the Sexually Violent Predator Act definition, and also, the State presented sufficient evidence to demonstrate Snow's diagnosis made him likely to engage in acts of sexual violence and that he had serious difficulty controlling his behavior. View "In the Matter of Snow" on Justia Law