Reiter v. State

Summary

The Wyoming Supreme Court upheld the constitutionality of Wyo. Stat. Ann. § 7-11-306(f), which places on a criminal acquittee the burden of proving by a preponderance of the evidence that he is fit for discharge. The court held that this burden does not violate due process because the acquittal establishes a basis for continued confinement while the acquittee remains mentally ill and dangerous. The court also held that criminal acquittees and civil committees are not similarly situated for equal-protection purposes.

Holdings

1. Requiring a criminal acquittee to rebut the presumption of continuing mental illness and dangerousness by proving fitness for discharge by a preponderance of the evidence does not violate state or federal due process.
2. Criminal acquittees and civil committees are not similarly situated individuals for equal protection purposes, so Wyoming may impose different burdens of proof in their discharge proceedings.
3. The district court did not misstate or apply an improper burden of proof when it denied Reiter's discharge application.

Questions Presented

1. Whether the district court applied an improper burden of proof in deciding Reiter's discharge application under Wyo. Stat. Ann. § 7-11-306(f).
2. Whether requiring a criminal acquittee to prove fitness for discharge by a preponderance of the evidence violates procedural or substantive due process under the United States and Wyoming Constitutions.
3. Whether treating criminal acquittees differently from civil committees with respect to the burden of proof in discharge proceedings violates equal protection.
4. Whether the district court's denial of Reiter's discharge application and declaratory judgment motion should be reversed.

Disposition

affirmed