Second Circuit
Bailey v. Pataki, 708 F.3d 391, 404-07 (2d Cir. 2013) (“The defendants offer no Supreme Court or Second Circuit precedent for the proposition that due process is satisfied if an individual in the plaintiffs’ position has the opportunity to request a hearing after he has been labeled an SVP and civilly committed.”).
Eighth Circuit
Beaulieu v. Ludeman, 07-CV-1535 JMR/JSM, 2008 WL 2498241, at *23 (D. Minn. June 18, 2008) (“Civilly committed individuals retain a fundamental interest in their safety and personal security, albeit not an absolute right, under the Due Process Clause. . . . This interest includes a clearly established right to not be exposed to unsanitary conditions.”).
Holly v. Anderson, 04-CV-1489 JMR/FLN, 2008 WL 1773093, at *8 (D. Minn. Apr. 15, 2008) (“Plaintiff’s allegations, if proven, would establish that Defendants Konieska and Smith knowingly violated Plaintiff’s Fourteenth Amendment Due Process rights by deliberately attempting to send the Plaintiff to jail.”).