Public outcry over ever increasing incidents of sexual violence encouraged a number of state legislatures to enact laws requiring the involuntary commitment of sexual predators.'Although sexually violent predator statutes date back at least fifty-five years, many states repealed their sexually violent predator statutes in the 1970s" as concern shifted from treating and rehabilitating individuals to prosecution and punishment of those individuals." 2 Modem sexually violent predator statutes differ substantially from the earlier treatment-oriented laws, because they mandate civil commitment for treatment and confinement subsequent to the completion of a criminal sentence. Currently, sixteen jurisdictions have sexually violent predator statutes. 3 These