L.P. v. Department of Children and Families

Appellant, Watson Marshall, timely appeals his civil commitment as a sexually violent predator. He raises numerous evidentiary errors, contending that the trial court erred in: (1) admitting victim hearsay statements to establish the factual basis for his underlying sexual crimes; (2) failing to find the Ryce Act hearsay exception unconstitutional; (3) admitting statistical evidence of screened prisoners recommended by the multidisciplinary team for involuntary commitment; and (4) permitting a psychologist to testify concerning the reasons a witness might not recall an act of sexual abuse committed during her childhood. For the reasons discussed below, we affirm.