In Kansas v. Crane (2002), the Supreme Court has clarified the Hendricks conditions for involuntary civil commitment of sexually violent predators. In addition to the mental illness and future danger requirements, the following condition was added:

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In Kansas v. Crane, the Supreme Court clarified that, in addition to proving that a person suffers from a mental illness and poses a future danger to the community, there must also be evidence that the person has serious difficulty in controlling behavior. This is to ensure that the civil commitment of sexually violent predators is constitutionally sound by demonstrating a lack of control over dangerous behavior, distinguishing them from individuals who simply have a history of criminality or mental illness.

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