After Hendricks: defining constitutional treatment for Washington State's Civil commitment program.

Washington State's law for sexually violent predators was enacted in 1990; since then, 14 other states have passed similar laws authorizing civil commitment for dangerous sexual offenders following their prison terms. Although the law has survived constitutional challenges at both the state and in the U.S. Supreme Court, a related set of court actions has addressed whether the treatment program is adequate. In 1994, the federal district court placed Washington's program under injunction and appointed a special master to ensure that the state improve deficiencies in the program. As of 2003, the federal court continues to oversee the state's program, with a threat of fines totaling several million dollars if the injunction terms are not met. Over an eight-year period, the special master delivered 19 reports to the court, documenting the program's deficiencies as well as its successes in meeting the court's orders. This article reviews these reports and court orders, detailing the court's requirements for an adequate treatment program.