William Walls was convicted of sexual assault of a minor in 1993 and sentenced to 15 years imprisonment. After his criminal sentence ended in 2003, Illinois filed a petition under the Sexually Violent Persons Commitment Act to civilly commit him, which was not resolved until 2015—a 12-year pretrial detention period.
In 2015, a state court found Walls to be a sexually violent person requiring civil commitment. He filed a federal habeas petition in 2017 challenging this decision but lost on procedural default grounds. After a 2018 state court review confirmed his continued commitment status, Walls filed another habeas petition, which the district court dismissed as an unauthorized successive petition.
The Seventh Circuit determined that Walls' second habeas petition was improperly challenging the 2015 commitment decision rather than the 2018 review. His principal argument was that Illinois unconstitutionally used statements he made during a prison sex offender treatment program in the civil commitment proceedings, violating his Fifth Amendment right against self-incrimination.
However, the court found this argument failed because the Illinois Supreme Court has held that sexually violent person proceedings are civil rather than criminal in nature, and no federal constitutional issues were properly raised regarding the 2018 proceedings. Since Walls was essentially re-challenging the 2015 decision, federal law prohibiting successive habeas petitions barred his claims.
The Seventh Circuit reserved its harshest criticism for the procedural delays in Walls' case. The court noted that after the 2015 commitment order, it took seven years for the state appellate court to resolve the appeal, with the case lying dormant for years without appointed counsel or deadlines. The court emphasized that 19 years elapsed from Walls' scheduled 2003 release until the 2022 appellate decision.
Judge Easterbrook's opinion stressed that while Walls was admittedly a difficult client who fired multiple lawyers and sometimes refused transport to court, the state judiciary must develop better procedures for handling mentally disturbed individuals subject to civil commitment. The court noted that civil commitment constitutes a significant liberty deprivation requiring due process protection, and referenced precedent allowing federal review when state remedial processes prove ineffective.