Summary
The Supreme Court held that Indiana could not indefinitely commit a criminal defendant solely because he was incompetent to stand trial when there was little or no likelihood that he would attain competency. Such commitment violated the Fourteenth Amendment's guarantees of equal protection and due process because it subjected the defendant to more lenient commitment standards and more stringent release standards than generally applicable civil commitment procedures. The Court reversed the judgment of the Supreme Court of Indiana.
Topics
Practice areas
Questions Presented
- Whether Indiana violated the Fourteenth Amendment's Equal Protection Clause by subjecting a criminal defendant found incompetent to stand trial to a more lenient commitment standard and a more stringent release standard than those generally applicable to persons not charged with offenses.
- Whether the Fourteenth Amendment's Due Process Clause permits a State to commit a criminal defendant indefinitely solely because he is incompetent to stand trial.
- Whether the Supreme Court should require dismissal of the criminal charges based on Jackson's alleged lack of criminal responsibility or the indefinite pendency of the charges.
Holdings
- Indiana violated the Equal Protection Clause by subjecting Jackson to a more lenient commitment standard and a more stringent release standard than those generally applicable to other citizens, thereby effectively condemning him to permanent institutionalization without the showing required for civil commitment or the corresponding opportunity for release.
- A person charged by a State with a criminal offense who is committed solely because of incapacity to proceed to trial may not be held longer than the reasonable period necessary to determine whether there is a substantial probability that the person will attain competency in the foreseeable future.
- The Supreme Court did not decide whether Jackson's criminal charges must be dismissed and remanded that issue for the Indiana courts to consider in the first instance.
Key quotations
“At the least, due process requires that the nature and duration of commitment bear some reasonable relation to the purpose for which the individual is committed.” (738)
“We hold, consequently, that 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 that capacity in the foreseeable future.” (738-739)
Factual background
Theon Jackson, a mentally deficient deaf mute with extremely limited communication skills, was charged with two robberies involving approximately four and five dollars. Psychiatric and interpreter testimony established that he could not understand the charges or participate in his defense and was unlikely ever to acquire the communication skills necessary for trial. Indiana committed him until he became competent, without periodic review or an alternative release standard, although the record showed little or no likelihood that he would ever attain competency.
Procedural history
Jackson was charged in the Criminal Court of Marion County with two robberies and pleaded not guilty. After a competency hearing, the trial court found him unable to understand the proceedings or assist in his defense and ordered him committed until he became sane. The Indiana Supreme Court affirmed, 253 Ind. 487, 255 N.E.2d 515 (1970), and denied rehearing; the United States Supreme Court granted certiorari.
Remand instructions
The Indiana courts were to determine whether the charges should be dismissed, including consideration of Jackson's criminal responsibility, speedy-trial claims, related due process concerns, and other defenses or pretrial motions that could fairly be resolved despite his incompetency. The State could either institute customary civil commitment proceedings or release Jackson if there was no substantial probability that he would attain competency within a reasonable period.