Jackson v. Indiana
406 U.S. 715 (1972)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The indefinite commitment of a criminal defendant solely on account of their incapacity to stand trial violates the Fourteenth Amendment. A state may only hold such a defendant for a reasonable period necessary to determine if there is a substantial probability that they will attain competency in the foreseeable future; otherwise, the state must either institute standard civil commitment proceedings or release the defendant.
Facts:
- Theon Jackson, a deaf-mute with the mental level of a pre-school child, could not read, write, or otherwise communicate except through limited sign language.
- In May 1968, Jackson, then 27, was charged with two separate robberies involving property valued at a total of nine dollars.
- After Jackson entered not-guilty pleas, the court initiated competency proceedings.
- Two court-appointed psychiatrists examined Jackson and concluded that his communication deficits and mental deficiency left him unable to understand the charges or participate in his defense.
- One psychiatrist testified that it was extremely unlikely Jackson could ever develop the necessary communication skills and that his "prognosis appears rather dim."
- The other psychiatrist testified that even without his hearing and speech impairments, Jackson's mental deficiency would render him incompetent to stand trial and doubted he would ever develop the required skills.
- An interpreter from a school for the deaf testified that Indiana had no facilities that could help a person with Jackson's severe disabilities learn minimal communication skills.
Procedural Posture:
- Theon Jackson was charged with two robberies in the Criminal Court of Marion County, Indiana, a state trial court.
- After a competency hearing, the trial court found Jackson lacked comprehension to make his defense and ordered him committed to the Indiana Department of Mental Health until he became "sane."
- Jackson's counsel filed a motion for a new trial, arguing the commitment violated his constitutional rights, but the trial court denied the motion.
- Jackson, as the appellant, appealed to the Supreme Court of Indiana, the state's highest court.
- The Supreme Court of Indiana affirmed the trial court's order, with the State of Indiana as appellee.
- The United States Supreme Court granted Jackson's petition for a writ of certiorari to review the decision of the Indiana Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the indefinite commitment of a criminal defendant, who is unlikely to ever attain the capacity to stand trial, based solely on his incompetency, violate the Equal Protection and Due Process Clauses of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Blackmun
Yes, the indefinite commitment of a criminal defendant solely on account of his incompetency to stand trial violates both the Equal Protection and Due Process clauses. Under the Equal Protection Clause, Indiana subjected Jackson to a more lenient commitment standard (inability to stand trial) and a more stringent release standard (regaining competency) than those applied to all other persons civilly committed, which require findings like mental illness or feeble-mindedness and offer release when custodial care is no longer needed. Citing Baxstrom v. Herold, the Court found that the mere pendency of criminal charges is not a sufficient justification for this disparity in treatment. Under the Due Process Clause, the nature and duration of confinement must bear a reasonable relation to its purpose. Since the purpose of committing an incompetent defendant is to restore their competency, indefinite commitment is impermissible once it is determined that there is no substantial probability the defendant will attain that capacity in the foreseeable future. Continuing the commitment beyond that point untethered to its original purpose is unconstitutional.
Analysis:
This landmark decision establishes crucial constitutional limits on the state's power to confine criminal defendants found incompetent to stand trial. It prevents states from using incompetency proceedings as a means for de facto life sentences without a criminal conviction. The ruling forces states to either treat incompetent defendants similarly to individuals in the civil commitment system, requiring proof of factors like dangerousness or need for care for long-term confinement, or release them. It effectively creates a requirement for periodic review of an incompetent defendant's status and prognosis, shifting the focus from indefinite confinement to either restoration of competency or resolution through the civil system.
