Frank v. United States
Headline: Insanity defense instruction question: Court denies review while Justice Stevens says new federal law requires juries be told mentally ill defendants will be hospitalized, easing jurors’ fears about release.
Holding: The Court denied review of the jury-instruction question, and Justice Stevens explained that the 1984 federal law requires hospitalization of defendants found not guilty by reason of insanity and that juries should be told this.
- Makes juries more willing to consider insanity defenses if told federal law ensures hospitalization.
- Encourages trial judges to consider giving instructions about post-verdict hospitalization.
- Does not change the law because the Court's denial is not a final decision on the substance.
Summary
Background
A federal criminal defendant who pleaded not guilty by reason of insanity sought a jury instruction explaining what happens after such a verdict. The Insanity Defense Reform Act of 1984 says the Attorney General must hospitalize a person found not guilty by reason of insanity until a State takes responsibility or the Attorney General finds release safe (18 U.S.C. § 4243(e)). The legal question is whether juries should be told about that automatic hospitalization when they consider an insanity defense.
Reasoning
The Court denied review of the case, but Justice Stevens wrote respecting that denial to explain the practical and legal points. He said juries might reject a legitimate insanity defense if they fear a dangerous person will go free. Before 1984, courts sometimes refused to give the instruction because no federal commitment law existed; courts in the District of Columbia required the instruction because a local statute existed there. Now that the 1984 federal law requires hospitalization, Stevens argued the District of Columbia rule should apply throughout the federal system, and refusing the instruction in a proper case can be clear legal error.
Real world impact
Stevens warned that telling juries about guaranteed hospitalization could make jurors more willing to accept a meritorious insanity defense and could guide trial judges to give such instructions. But because the Court simply denied review, this opinion is not a final decision on the substance and does not change the law nationwide. The Court noted it typically waits for a split among appeals courts before resolving such new statutory questions.
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