15 N.Y.3d 126 (2010)
Mental Hygiene Law Article 10, concerning civil management of detained sex offenders, applies to individuals physically in the custody of the Department of Correctional Services (DOCS) with respect to a sex offense, even if their detention arises from an improperly imposed term of post-release supervision (PRS).
Summary
This case addresses whether Mental Hygiene Law Article 10 applies to sex offenders whose imprisonment stems from violating conditions of PRS terms unlawfully added to their sentences by DOCS. Joseph II and Humberto G. were convicted of sex offenses and, though the sentencing courts failed to impose PRS terms, DOCS included them. After completing their prison sentences, both violated the conditions of their PRS while in psychiatric hospitals and were reincarcerated. When prosecutors declined to seek resentencing following decisions clarifying the impropriety of DOCS adding PRS terms, the state initiated Article 10 proceedings. The Court of Appeals held that Article 10 applies to these prisoners, emphasizing the statute’s focus on those physically detained, regardless of the legality of the detention’s basis. The Court reasoned that the legislature intended to treat all prisoners similarly under Article 10, irrespective of whether their custody was lawful.
Facts
Joseph II and Humberto G. were convicted of sex offenses and sentenced to prison. The sentencing courts did not pronounce terms of post-release supervision (PRS), although PRS was required by statute. DOCS administratively added PRS terms to both men’s sentences. Upon release, both men were admitted to psychiatric hospitals. Joseph violated his PRS by attempting to escape, and Humberto by assaulting a patient. Both were reincarcerated for these violations.
Procedural History
After the State began Article 10 proceedings, Joseph filed a habeas corpus petition, which was initially dismissed by the Supreme Court but later granted by the Appellate Division. Humberto moved to dismiss the Article 10 proceeding against him, which was granted by the Supreme Court and affirmed by the Appellate Division. The Court of Appeals granted leave to appeal in both cases.
Issue(s)
Whether Mental Hygiene Law Article 10 applies to individuals imprisoned for violating the conditions of post-release supervision (PRS) terms that were unlawfully imposed by the Department of Correctional Services (DOCS).
Holding
Yes, because Article 10 applies to individuals physically in the custody of DOCS with respect to a sex offense, regardless of whether the basis for their detention is legally sound.
Court’s Reasoning
The Court reasoned that the definition of “detained sex offender” in Mental Hygiene Law § 10.03(g) focuses on the person being in the “care, custody, control, or supervision of an agency with jurisdiction.” The Court found that Joseph and Humberto were in DOCS custody with respect to sex offenses when the Article 10 proceedings began. The Court rejected the argument that