A pedophile was properly denied release from involuntary commitment where he had refused treatment and failed to recognize that his actions were harmful. As such, the Supreme Court of Montana held that the evidence supported a conclusion that he was dangerous and affirmed a district court's denial of the patient's petition for release from the state hospital.

Paul Woods was charged with felony sexual assault stemming from alleged encounters with several young boys. A psychiatric evaluation given prior to trial diagnosed Woods as suffering from "borderline retardation" and "other sexual deviation." As a result of these findings, Woods was deemed incompetent to stand trial and acquitted of the charge against him by reason of mental disease or defect. The court committed Woods to a state hospital. Some years later, and after some supervised releases with his family, Woods petitioned for an unconditional release from the hospital.

Evidence presented during Woods' hearing revealed that at the time of the hearing he continued to suffer from pedophilia. One psychiatrist opined that Woods was in remission and recommended his release. However, another psychiatrist determined that Woods could not be recommended for release as he did not appreciate that his actions were harmful, and had refused treatment. Specifically, Woods, with a little coaxing, would make statements to the effect that there was nothing wrong with his conduct and that he felt justified in his actions. In fact, he would state his belief that the children's parents were doing the same things to the children that he had done. Additionally a letter from Woods' sisters was produced in which they related that Woods had made inappropriate comments to a young boy during a period in which he had been conditionally released from the hospital. Woods' petition was ultimately denied. He appealed, alleging that the state failed to present clear and convincing evidence that he suffered from a mental disease or defect which rendered him dangerous, the applicable standard for commitment under Montana law.

The Supreme Court of Montana disagreed. Pointing out that all of the experts in the case testified that Woods was a pedophile, and that due to his resistance he had not received treatment, the court held that evidence supported the lower court's finding of mental illness. To the court, the fact that Woods showed signs of remission did not prevent such a finding; in fact, it supported an inference that the condition still existed.

Turning to Woods' dangerousness, the court reasoned that the risk that Woods might harm young males if released was sufficient to deem him dangerous under the statute. Specifically, the court relied on expert testimony regarding the fact that Woods had refused treatment during the course of his commitment and failed to recognize the harm of his actions. Additionally, an expert had testified that the fact that Woods may have showed signs of being in remission can be largely attributable to the fact that he had been limited to situations where he was in controlled environments (i.e. the hospital and with his family) where he had little opportunity to exhibit pedophilic behavior.