Minnesota Law Review
Thomas Steele pleaded guilty to rape and other charges in exchange for a sentence of twelve to thirty years in a Massa- chusetts state prison.' Shortly before he became eligible for pa- role on this criminal conviction, the state classified Steele as a "sexually dangerous person." Although Steele has completed his prison sentence, the state continues to confine him under a Massachusetts law that allows for the involuntary civil com- mitment of "sexually dangerous persons." The order commit- ting him stated that he could be held for a period ranging from one day to life.
Roberts, Jenny M., "The Mythical Divide Between Collateral and Direct Consequences of Criminal Convictions: Involuntary Commitment of "Sexually Violent Predators"" (2008). Articles in Law Reviews & Other Academic Journals. 287.