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unreasonable…”). Hallford v. State, 289 Ga.App. 350, 657 S.E.2d 10 (January 8, 2008). Footnote: “[T]he Georgia Supreme Court has held that the constitutional prohibition against ‘banishment beyond the limits of the state’ (see 1983 Ga. Const., Art. I, Sec. I, Par. XXI) does not prohibit banishment from specified areas within the State. See State v. Collett, 232 Ga. 668, 670 (208 S.E.2d 472) (1974).” “Banishment from counties within the State has been upheld as a reasonable condition of probation. Adams v. State, 241 Ga.App. 810, 811 (527 S.E.2d 911) (2000) (banishment from judicial circuit for 30-year term of sentence not unreasonable); Wyche v. State, 197 Ga.App. 148, 149(2) (397 S.E.2d 738) (1990) (banishment from five counties not unreasonable as it removed ‘the offender from a locale in which he previously succumbed’ to criminal activity); Parrish v. State, 182 Ga.App. 247, 248(2) (355 S.E.2d 682) (1987) (banishment from judicial circuit, motivated by concerns for the safety of others in the community and the defendant’s own safety, was reasonable). Such banishment may be improper, however, if it is ‘unreasonable or otherwise fails to bear a logical relationship to the rehabilitative scheme of the sentence.’ Collett, supra, 232 Ga. at 671. It was shown at the sentencing hearing that Hallford’s crimes were likely motivated by his relationship with the victim, his ex-wife, and the trial court explicitly referenced his consideration of the victim’s residence and place of employment, as well as the residences of her immediate family, in determining which counties Hallford’s banishment would include. Such consideration not only protects the victim and her family but also serves a rehabilitative purpose by removing a temptation by Hallford to re-offend. Accordingly, ‘[n]o abuse [of discretion] is shown which requires our interference.’ Parrish, supra, 182 Ga.App. at 248(2).” Accord, Adams v. State , 298 Ga.App. 518, 680 S.E.2d 429 (May 27, 2009) (banishment from one county not illegal). F. CHEMICAL CASTRATION Johnson v. State, 280 Ga.App. 341, 634 S.E.2d 134 (July 10, 2006). Trial court erred in sentencing defendant to chemical castration after conviction for rape. “Our law only permits this punishment in cases when the person sentenced has been convicted of child molestation or aggravated child molestation. See OCGA §§ 16-6-4(d)(2) and 42-9-44.2(a).” G. CIVIL COMMITMENT Seminal case: Kansas v. Hendricks, 521 U.S. 346, 117 S.Ct. 2072, 138 L.Ed.2d 501 (1997). Kansas v. Crane , 534 U.S. 407, 122 S.Ct. 867, 151 L.Ed.2d 856 (January 22, 2002). Reversing Kansas Supreme Court. State statute providing for civil commitment of sexually violent predators doesn’t violate due process when “(1) ‘the confinement takes place pursuant to proper procedures and evidentiary standards,’ (2) there is a finding of ‘dangerousness either to one's self or to others,’ and (3) proof of dangerousness is ‘coupled ... with the proof of some additional factor, such as a “mental illness” or “mental abnormality,”’” quoting Kansas v. Hendricks, 521 U.S. 346, 357-358, 117 S.Ct. 2072, 138 L.Ed.2d 501 (1997). 1. Contrary to Kansas Supreme Court ruling here, Hendricks doesn’t require “the State always to prove that a dangerous individual is completely unable to control his behavior.” Rather, “ Hendricks set forth no requirement of total or complete lack of control. Hendricks referred to the Kansas Act as requiring a ‘mental abnormality’ or ‘personality disorder’ that makes it ‘ difficult, if not impossible, for the [dangerous] person to control his dangerous behavior.’ 521 U.S., at 358, 117 S.Ct. 2072 (emphasis added).” Some lack-of- control determination is required, however. “It is enough to say that there must be proof of serious difficulty in controlling behavior. And this, when viewed in light of such features of the case as the nature of the psychiatric diagnosis, and the severity of the mental abnormality itself, must be sufficient to distinguish the dangerous sexual offender whose serious mental illness, abnormality, or disorder subjects him to civil commitment from the dangerous but typical recidivist convicted in an ordinary criminal case. 521 U.S., at 357-358, 117 S.Ct. 2072; see also Foucha v. Louisiana, 504 U.S. 71, 82-83, 112 S.Ct. 1780, 118 L.Ed.2d 437 (1992) (rejecting an approach to civil commitment that would permit the indefinite confinement ‘of any convicted criminal’ after completion of a prison term).” 2. Also contrary to Kansas Supreme Court’s holding, Hendricks does not “consider whether confinement based solely on ‘emotional’ abnormality [as opposed to ‘volitional’] would be constitutional, and we likewise have no occasion to do so in the present case.” Seling v. Young, 531 U.S. 250, 121 S. Ct. 727, 148 L.Ed.2d 734 (January 17, 2001). Reversing Ninth Circuit; Young’s habeas petition should have been denied, as his confinement under Washington State’s statute relating to “sexually violent predators” was civil, not criminal, and thus not violative of the Double Jeopardy or Ex Post Facto Clauses. Recognizing that Washington’s Supreme Court “had already held that the [confinement statute] was civil, Young filed federal habeas contending that the statute was punitive as applied to him. Ninth Circuit agreed that he could bring such a claim, but U.S. Supreme Court reverses, saying that such an approach is improper, based on Hudson v. United States, 522

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