10, subd. 1. The commitment statute requires proof by clear and convincing evidence. Minn.Stat. §§ 526.10, 253B.18, subd. 1; see In re Monson, 478 N.W.2d 785, 788 (Minn.App. 1991). In State ex rel. Pearson v. Probate Court of Ramsey County, 205 Minn. 545, 287 N.W. 297 (1939), aff'd, 309 U.S. 270, 60 S.Ct. 523, 84 L.Ed. 744 (1940), the Minnesota Supreme Court narrowed the definition of a psychopathic personality as:

Cf. In re Monson, 478 N.W.2d 785, 789 (Minn.App. 1991) (stating, in terms of the lack-of-control criterion of the SPP statute, that the "statute does not address convictions; it addresses behavior," and that appellant's nonadjudicated acts of sexual abuse supported the criterion). Thus, the nonadjudicated behavior relied on by Dr. Dority was supported in significant part by firsthand witness testimony at the trial; testimony that was subject to cross-examination and impeachment by White.

01; In re Joelson, 385 N.W.2d 810, 811 (Minn. 1986); In re Monson, 478 N.W.2d 785, 788 (Minn.App. 1991). Nevertheless, whether the record supports the standards for commitment with clear and convincing evidence is a question of law, which we review de novo.

A trial court's findings of fact will not be reversed unless clearly erroneous. In re Monson, 478 N.W.2d 785, 788 (Minn.App. 1991). I.

According to Dr. William D. Erickson, Medical Director of the St. Peter Regional Treatment/Minnesota Security Hospital, persons have been committed as psychopathic personalities for a very wide range of behaviors, including window peeping, excessive masturbation, "sexual contact with cows," homosexuality, incest, pedophilia, and rape. Erickson, supra note 1, at 20-26. Furthermore, many courts in subsequent cases have not followed the narrow judicial definition of "psychopathic personality" adopted in Pearson but have used instead the statutory definition as written. See, e.g., Dittrich v. Brown County, 215 Minn. 234, 235, 9 N.W.2d 510, 511 (1943); In re Martenies, 350 N.W.2d 470, 472 (Minn.Ct.App. 1984); In re Stone, 376 N.W.2d 511, 513 (Minn.Ct.App. 1985); In re Brown, 414 N.W.2d 800, 803 (Minn.Ct.App. 1987); In re Clements, 440 N.W.2d 133, 136 (Minn.Ct.App. 1989); In re Monson, 478 N.W.2d 785, 788-89 (Minn.Ct.App. 1991). In the more than half a century since its holding in Pearson, the United States Supreme Court has decided a number of cases involving a state's power to confine individuals without a criminal conviction.

In re Civ. Commitment of Crosby, 824 N.W.2d 351, 358 (Minn.App. 2013). Accordingly, "[i]ncidents establishing a course of harmful sexual conduct need not be recent and are not limited to those that resulted in a criminal conviction." Williams, 735 N.W.2d at 731; see also In re Monson, 478 N.W.2d 785, 789 (Minn.App. 1991) (holding habitual course of sexual misconduct required for psychopathic personality commitment was met where multiple acts of sexual abuse occurred, although appellant had only one conviction for criminal sexual conduct).

Although Difronzo has only three convictions of criminal sexual conduct, the number of convictions an individual has is not dispositive of whether the criteria are met for commitment as an SDP. In re Monson, 478 N.W.2d 785, 789 (Minn. App. 1991). In this case, the evidence demonstrates that Difronzo has had 100 to 150 sexual partners, at least 20 to 30 of whom were victims of sexual misconduct. The specific convictions carry a presumption of harm, Minn. Stat. § 253B.02, subd. 7a(b), and the district court's conclusion that Difronzo's other victims—all of whom were juveniles—likely experienced serious physical or emotional harm is supported by the record, which includes Difronzo's acknowledgment that his sexual offenses have involved force, coercion, and manipulation against vulnerable victims.

The district court abused its discretion in concluding that the vacation of respondent's 2004 conviction was a change in circumstances that justified the vacation of his commitment because indeterminate commitment is based not on an individual's convictions, but on his acts. See Minn. Stat. § 253B.02, subd. 18c (2008) (defining SDP not in terms of convictions but rather as person who has engaged in course of harmful sexual conduct, has manifested qualifying disorder or dysfunction, and, as result, is likely to engage in acts of harmful sexual conduct); see also In re Monson, 478 N.W.2d 785, 789 (Minn. App. 1991) (rejecting argument that commitment as psychopathic personality was not justified because appellant had been "convicted of sexual misconduct only once" and holding that commitment "statute does not address convictions; it addresses behavior, which in appellant's case clearly showed multiple acts of sexual abuse against young boys"). Here, respondent testified about his sexual activity with young girls, including the incident that led to the vacated conviction.

We have previously held that the sheer number of convictions that an individual has is not dispositive of whether he meets the criteria for commitment as an SDP. In re Monson, 478 N.W.2d 785, 789 (Minn. App. 1991). Likewise, the lack of prior criminal convictions is not determinative. Based on the extensive record of appellant's long history of inappropriate sexual behavior, we conclude that sufficient clear and convincing evidence supports the district court's determination that appellant engaged in a course of harmful sexual conduct. The district court was in the best position to judge the credibility of the victims' testimony and the experts' findings in light of the entire record.

Id. The commitment statute focuses on behavior, not convictions. In re Monson, 478 N.W.2d 785, 789 (Minn.App. 1991). And by his own account, Parks's sexual misconduct constituted a series of abuses until his incarceration finally prevented him from contacting children.