State v. Matthew A.B., 231 Wis.2d 688, 605 N.W.2d 598 (Ct. App. 1999)
For Matthew A.B.: Mary E. Waitrovich, SPD, Madison Appellate.
Issue/Holding: Prediction of future dangerousness may be made of a juvenile in a Ch. 980 proceeding.
The state’s experts assessed Matthew’s dangerousness by using the “Doren criteria,” which were developed through research involving adults. Moreover, Matthew adduced evidence “that juveniles have a lower propensity to reoffend in sexual violence situations.” Nonetheless, the court of appeals advances three reasons for finding no violation of due process. 1) The state’s experts acknowledged the limitations of the Doren research, and discounted its applicability to juveniles. 2) Flaws in the Doren criteria would go only to weight not admissibility. 3) Matthew’s future dangerousness was based on all the evidence , such as his history, not just the Doren criteria. ¶¶33-35.