Citation. 435 U.S. 975, 98 S. Ct. 1623, 56 L. Ed. 2d 69 (1978)
Law Students: Don’t know your Studybuddy Pro login? Register here Brief Fact Summary.
Appellant was arrested for robbery and committed to State care until he is competent to stand trial. Appellant’s representative argued that he would never be competent and thus would be committed forever in violation of his constitutional rights.
Synopsis of Rule of Law.
If a defendant is deemed never competent to stand trial, the State must institute a civil commitment preceding that it would institute for any other citizen or release the defendant.
Facts.
Appellant was a mentally deficient deaf mute with a mental level of a pre-school child. He could not read, write or communicate. Appellant was charged with robbery of two different women. Appellant robbed the women for four and five dollars respectively. Appellant was found to be incompetent to stand trial at an incompetency hearing. The Court ordered Appellant to be committed until he was competent to stand trial.
Issue.
Whether Appellant’s Constitutional rights were violated.
Whether Indiana’s pre-trial commitment violated Appellant’s equal protection rights by committing him on a more stringent standard than other civil commitment proceedings.
Whether Appellant’s due process rights were violated based on his indefinite commitment based solely on his inability to stand trial.
Held.
Reversed and Remanded.
Appellant was subject to a more lenient commitment standard but a more stringent standard for release from commitment than others not charged with an offense and thus violated Appellant’s right to equal protection.
A person charged by a State with a criminal offense who is committed solely on account of his incapacity to proceed to trial cannot be held more than the reasonable period of time necessary to determine whether there is a substantial probability that he will attain the capacity in the foreseeable future.
If it is determined that a defendant will never be deemed competent to stand trial, the State must either institute the customary civil commitment proceeding that would be required to commit indefinitely any other citizen or release a defendant.
Discussion.
In determining whether Appellant was denied equal protection under the Constitution, the Court focused on the testimony of medical experts which determined that Appellant would never be competent to stand trial. Therefore, Appellant’s commitment was, in effect, permanent. The Court next addressed whether the charges against Appellant should be dismissed. This would depend on whether the Court determines that Appellant was capable of a criminal intent at the time of the crimes. If he was not, dismissal of the charges might be warranted.
