In Wrenn v. Benson et al., 1988, the U.S. Supreme Court was asked to consider whether a state law that allowed for the involuntary commitment of individuals deemed sexually dangerous violated their constitutional rights. The petitioner, Wrenn, had been committed under this law and argued that it infringed upon his right to due process and equal protection under the Fourteenth Amendment because he was being punished without having been convicted of a crime. He also claimed that his Fifth Amendment rights against self-incrimination were violated as he was required to participate in treatment programs where he would have to admit guilt for sexual offenses. The court ruled against Wrenn's claims stating that civil commitment statutes are not punitive but rather aim at protecting society from harm while providing care and treatment for those who need it most. It further held that requiring participation in therapy does not violate Fifth Amendment protections since these admissions cannot be used as evidence in criminal proceedings.

The dissenting opinion in the case of WRENN v. BENSON et al., 1988, argued that the majority's decision to uphold a lower court ruling against a police officer who had used excessive force was misguided. The dissenters believed that the officer should have been granted qualified immunity, which would protect him from being sued for actions taken while performing his duties as long as those actions did not violate clearly established statutory or constitutional rights. They contended that at the time of the incident, it was not clearly established law that an officer could be held liable for using deadly force against a fleeing suspect who posed no immediate threat to others. Therefore, they asserted, he should have been shielded from liability under qualified immunity doctrine.