BAKER, J.
¶ 1 Deryle Hovinga appeals his commitment as a sexually violent predator, arguing that the State was required to plead and prove to the jury that he committed a recent overt act. He also argues that the superior court erred by precluding the defense expert from testifying about an e-mail that the defense received mid-trial. Because Hovinga was incarcerated for a recent overt act at the time the State filed the commitment petition, the State was not...
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