Florida v. Garrett

Background

A man charged with first‑degree murder of a police officer was found incompetent to stand trial in 1970 and committed to a state hospital. Three psychiatrists diagnosed paranoid schizophrenia and repeatedly found him dangerous. Over six years the trial court held multiple competency hearings. Medication often restored his ability to stand trial, but the court ordered medication withdrawn, the defendant regressed, and he was recommitted. In 1977 Florida enacted a law allowing judges to decide competency while a defendant is medicated. The defendant later pleaded nolo contendere and appealed, arguing a violation of his right to a speedy trial; the Florida District Court of Appeal reversed his conviction, relying on Jackson v. Indiana.

Reasoning

The core question was whether the Florida appellate court properly relied on Jackson to reverse the conviction because of the length of pretrial commitment. Justice Rehnquist’s dissent explains that Jackson addressed only indefinite confinement imposed solely because of incompetency and turned on comparisons with other state commitment rules. He stressed that this defendant had been repeatedly found dangerous, pointed to Greenwood as treating dangerousness differently, and noted Florida’s new statute permitting competency findings while medicated. Rehnquist concluded the State’s facts and statutory differences make Jackson inapplicable and the appellate court misread that precedent.

Real world impact

Because the Supreme Court denied review, the Florida appellate reversal stands and the defendant’s conviction remains overturned. The decision leaves unanswered how courts should treat long pretrial hospitalization, competency restored by medication, and related speedy‑trial claims. The dissent warns lower courts may repeat the same legal error if not corrected.

Dissents or concurrances

Justice Rehnquist, joined by the Chief Justice, dissented and would have granted review to correct what he saw as a mistaken application of Jackson v. Indiana.