A unanimous panel of the Appellate Division, First Department, overruled a finding that a 67-year-old man who had completed a 33-year prison term for a string of rapes should be subject to intensive supervision and treatment after release.

Justice Dianne Renwick (See Profile) addressed the proof standards required under the Mental Hygiene Law Article 10, which allows civil commitment of sex offenders, in light of the recent Court of Appeals holding in Matter of State of New York v. Donald DD, 24 NY3d 174 (2014) (NYLJ, Oct. 30).