加拿大、美国和英格兰威尔士的危险和高风险犯罪者框架对比

Dangerous and high-risk offender regimes sit at the intersection of psychiatry, criminal law, and human rights. This article compares Canada's dangerous and long-term offender provisions, the United States's sexually violent predator laws, and the dangerousness framework in England and Wales. We review their historical development, statutory foundations, leading cases, and the role of forensic psychiatric evidence in assessments of future risk, manageability, and treatability. Across jurisdictions, psychiatry remains central to decisions with profound liberty consequences, yet each system reso