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____ confirmed that an individual who is not incarcerated at the time of a referral must have committed a recent overt act to indicate that he/she may require incapacitation. In addition, it confirmed that dangerousness alone is not enough for confinement; an offender needed to have a mental disability too. a. Kansas v. Hendricks (1997) b. O'Connor v. Donaldson (1975) c. Foucha v. Louisiana (1992) d. In re Young (1993)
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