In Re Detention Of: Louis W. Brock

CourtCourt of Appeals of Washington
DecidedSeptember 2, 2014
Docket68664-0
StatusPublished

This text of In Re Detention Of: Louis W. Brock (In Re Detention Of: Louis W. Brock) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Detention Of: Louis W. Brock, (Wash. Ct. App. 2014).

Opinion

IN THE COURT OF APPEALS FOR THE STATE OF WASHINGTON

IN RE DETENTION OF ] ) No. 68664-0-1 r

"^H ?—

DIVISION ONE r/3

!

LOUIS W. BROCK, PUBLISHED OPINION .-a t'lrn]

Respondent. ) FILED: September 2. 2014 r~ O oo

CD CO

Spearman, C.J. — In this case we consider whether a sexually violent

predator (SVP) under Chapter 71.09 RCW may waive his or her right to annually

petition for unconditional release by written agreement with the State. We

conclude that so long as the waiver is shown to be knowing, intelligent and

voluntary, a SVP may agree to waive the right to petition for unconditional

release. Accordingly, the agreement at issue in this case is lawful and

enforceable. We reverse.

FACTS

In 1991 Louis Brock was committed to the Special Commitment Center

(SCC) following a jury determination that he met the definition of a SVP1 under chapter 71.09 RCW.2 In November 2007, Brock filed a motion for a new trial on

1"Sexually violent predator" means any person who has been convicted of or charged with a crime of sexual violence and who suffers from a mental abnormality or personality disorder which makes the person likely to engage in predatory acts of sexual violence if not confined in a secure facility. RCW 71.09.020(18). 2 For a brief summary of Brock's criminal history, see Tagqart v. State, 118 Wn.2d 195, 199-201, 822 P.2d 243 (1992). No. 68664-0-1/2

whether he should be unconditionally released from the confinement. The trial

court granted the motion on February 28, 2008. At Brock's new trial, which began

in March 2010, the State offered testimony from Dr. Paul Spizman, an evaluator

at the SCC. He testified that because Brock suffered from a mental abnormality

and personality disorder which made him likely to engage in predatory acts of

sexual violence, he met the definition of a SVP. After hearing Dr. Spizman's

testimony and based on the advice of his attorneys, Brock concluded that it was

unlikely he would win unconditional release at trial. He also decided a conditional

release from confinement would more likely result from negotiating with the State

than by a jury trial. Before the second day of testimony resumed, the parties

notified the court they were attempting to settle the case. Later that same day,

Brock and the State entered into a settlement agreement ("the Agreement").

The Agreement required Brock and the State to each use their "best

efforts" to explore, develop, and craft an appropriate less restrictive placement

alternative (LRA) that would be acceptable to the SCC. Clerk's Papers (CP) at

234. In exchange, Brock agreed that "he currently continues to meet the criteria

for and the definition of a [SVP]." CP at 233. He also agreed to waive his

"statutory and any constitutional right to seek, petition [for] or accept an

unconditional release or removal of his designation as a [SVP] for a period of four

(4) years from the date of [the] Order." CP at 234, U 6 ("Paragraph Six"). This

promise extended to any unconditional release that might be recommended by

the SCC. Brock's counsel told the court that she had read the Agreement to

Brock word for word with particular emphasis on Paragraph Six. She stated that No. 68664-0-1/3

Brock indicated he understood the agreement and "he specifically agreed to that

provision [Paragraph Six] as well." Verbatim Report of Proceedings (3/4/10) at

307. The court questioned Brock about his understanding of the Agreement and

whether he was entering into it knowingly, intelligently and voluntarily. Brock

answered "Yes." to both questions.3 VRP (3/4/10) at 310-11. The court approved

the Agreement as in the interest of justice. The parties filed the Agreement,

signed by Brock, counsel for both sides, and the court. The jury was dismissed

and the trial ended.

Seven months later, Dr. Spizman conducted an annual review of Brock, as

required by statute. Based on this evaluation, Dr. Spizman "ha[d] significant

uncertainty whether [Brock continued to have] a mental abnormality." CP at 147.

He thus concluded Brock no longer met the criteria for continued involuntary

commitment. Brock did not petition for unconditional release at that time.

A year later, after the October 2011 annual review, Dr. Spizman was again

"unable to clearly identify an underlying mental abnormality/personality disorder

that would meet the criteria necessary for Mr. Brock to be civilly committed as a

Sexually Violent Predator." CP at 191. He also questioned the degree of risk

Brock posed if he was released from confinement, opining "I cannot state [Brock]

continues to be more likely than not to reoffend sexually if released

unconditionally from confinement." ]d.

3 The court stated, "[SCC] might submit a report saying that they don't believe that you're a sexually violent predator within those four years, and that you should be released unconditionally, that you by this paragraph, if that happened, are"agreeing that you would not seek an unconditional release or attempt to have you designated as not being a sexually violent predator. Do you understand that?" Brock answered, "Yes, I do." VRP (3/4/10) at 311-12. No. 68664-0-1/4

On November 10, 2011, less than two years after signing the Agreement,

Brock filed a memorandum, citing Dr. Spizman's report, in support of his request

for a trial on whether he should be unconditionally released. The State objected

to the request. It argued that, regardless of Dr. Spizman's opinion, the

Agreement precluded Brock from seeking unconditional release until 2014.

In March 2012, Brock filed a motion to strike, withdraw or otherwise not

enforce the stipulation, contending the agreement was unenforceable because it

usurped the authority of the court and because the agreement was

unconscionable. The State opposed the motion. It contended that because Brock

was seeking relief from a judgment or order, the motion was properly analyzed

under CR 60. The State pointed out that Brock had not shown that any of the

bases listed in CR 60(b)(1)-(10) applied. Accordingly, it argued, the motion

should be denied. In reply, Brock clarified that his request for relief was not

based on CR 60(b).

The court granted Brock's motion and entered an order striking Paragraph

Six of the Agreement.4 The court concluded Brock was entitled to relief because

Paragraph Six violated "public policy by allowing continued confinement of Mr.

Brock when he no longer meets the definition of a SVP." CP at 42. The court

further found that "the waiver of a right to accept unconditional release after

future annual reviews with unknown results is contrary to law because those

future annual reviews may not support continued confinement in the SCC." CP at

4 Because the judge who presided over the aborted trial had retired, the motion was heard by a different judge. No. 68664-0-1/5

42. Although Brock expressly denied that he sought to vacate the Agreement

under CR 60(b), the court also granted relief under CR 60(b)(11) concluding that

under the circumstances, Brock's continued confinement without a right to seek

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