Jackson v. Indiana
Headline: Limits state power to indefinitely hold people found unfit for trial, ruling Indiana may not keep an incompetent, disabled defendant locked up without civilian commitment or a reasonable chance to regain competence.
Holding: The Court held Indiana may not indefinitely commit a defendant solely for trial incompetence; the State must allow a reasonable time to regain competence and otherwise use ordinary civil commitment procedures or release him.
- Prevents states from permanently committing incompetent defendants without civil commitment standards.
- Requires periodic review or civil commitment procedures if no chance of regaining competence.
- May lead courts to dismiss charges or hold special hearings for incompetent defendants.
Summary
Background
A 27-year-old deaf, mentally deficient man charged with two small robberies was found unable to understand the charges or to assist in his defense. After two psychiatrists and an interpreter testified that he lacked basic communication skills and was unlikely to improve, the trial court ordered him committed under Indiana's pretrial law until the state hospital certified him "sane." He has been confined about three and one-half years on this basis. His lawyer argued this indefinite commitment violated his rights under the Fourteenth and Eighth Amendments.
Reasoning
The Court examined whether Indiana's pretrial commitment procedure, which allows commitment "until sane" without periodic review or the civil-commitment protections, could be applied to someone with little chance of ever becoming competent. Comparing other Indiana statutes for civil commitment and prior cases such as Baxstrom and Greenwood, the Court found the record showed minimal prospect of improvement and that the State treated him less favorably than others who would be committed under ordinary civil procedures. The Court held that indefinite commitment solely for trial incompetence violates equal protection and due process when no substantial probability exists that the defendant will regain capacity.
Real world impact
States cannot automatically lock up an incompetent criminal defendant indefinitely; they must allow a reasonable period to determine if competence will be restored. If restoration is unlikely, the State must either use its usual civil-commitment procedures or release the person. The Indiana courts were instructed to reconsider the charges and possible procedures on remand.
Dissents or concurrances
The Indiana Supreme Court had affirmed with one dissent and rehearing was denied with two dissenters; two U.S. Justices did not participate.
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