In the Matter of the Care and Treatment of Jeffrey Allen Chapman, Appellant

Summary

The South Carolina Supreme Court held that individuals civilly committed as sexually violent predators have a constitutional right to effective assistance of counsel, which may be vindicated through a habeas corpus proceeding, and affirmed Chapman’s commitment while allowing him to raise ineffective‑assistance claims later. The Court applied the Strickland two‑prong test to evaluate counsel’s performance. Justice Few dissented, arguing the majority exceeded its constitutional authority by creating procedural rules beyond its jurisdiction.