Jackson v. Indiana
Encyclopedia
Jackson v. Indiana was a landmark decision
of the U.S. Supreme Court that determined a state
violated due process
by involuntarily committing
a criminal defendant for an indefinite period of time solely on the basis of his permanent incompetency to stand trial
on the charges filed against him.
may be made in which the charges are nolle prossed if the defendant agrees to seek treatment. Otherwise, the defendant is usually committed to a psychiatric hospital
for treatment until the defendant is restored to competency, at which point the trial will proceed.
who could not read, write or communicate in other ways, was charged with two counts of petty theft. Competency evaluations
and testimony
by the evaluating doctors showed that Jackson's intelligence was too low for him to understand the nature of the charges against him, even if he were able to develop the ability to communicate, and that the prognosis for restoration of competency was "rather dim" even if he were not a deaf mute. Despite testimony that the state of Indiana
had no facilities to treat Jackson's problems, Jackson was committed
to a psychiatric hospital
for treatment.
Appealing on a writ of certiorari
to the Supreme Court of Indiana, the petitioner Jackson argued that his commitment was equal to a "life sentence" even though he had not been convicted of a crime. The petitioner claimed he was being denied equal protection because, without the criminal charges pending against him, the State would have been required to proceed using Indiana's statutory provisions for the feeble-minded
or for the mentally ill. Under these provisions Jackson would have been entitled to greater rights. He also claimed that what was essentially an indefinite commitment deprived him of due process
and subjected him to cruel and unusual punishment
. However, the State Supreme Court affirmed the denial of the lower court. A rehearing was also denied. The U.S. Supreme Court granted certiorari
.
clauses of the Fourteenth Amendment
.
The Court examined Indiana procedure of pretrial commitment of incompetent criminal defendant as set forth in Ind. Ann. Stat. 9-1706a and compared it with the procedures for committing persons who are "feeble-minded
, and are therefore unable properly to care for themselves" and those for the "mentally ill". The Court found the procedures were essentially similar with one important difference. A person committed as "feeble-minded" may be released "at any time" his condition warrants it in the judgment of the superintendent of the institution. A person committed as "mentally ill" may be released when the superintendent of the institution discharges him, or when he is cured. Committing the criminal defendant indefinitely violates equal protection.
Therefore, the Court ruled that Indiana's indefinite commitment of a criminal defendant solely because he lacks the capacity to stand trial violates due process.
The Court declined to rule on the issue of the pending charges themselves, reasoning that the issue of petitioner's criminal responsibility at the time of the alleged offenses has not yet been adjudicated, and therefore it would be premature for the Court to dismiss the charges against petitioner.
of incompetent
individuals often meant lengthy or even lifetime confinement in a maximum security institution with little concern for treatment. This was true even though they were neither tried for or convicted of a crime. In this case, the Court for the first time put limits on the length of time an incompetent person may be confined. However, the court offers only general guidelines and by 1994, twenty years after the case, 32 states still had not enacted periodic judicial review of incompetent detainees. Many states still allowed a detention period that exceeded that maximum sentence that person would have received if convicted.
Further, by refusing to rule on the charges themselves, the court did not clarify the proper disposition of criminal charges pending against a person whose competency can not be restored. This means that in those states where the charges are not dismissed, the individual may not be converted to a civil status eligible for civil commitment, resulting in such an individuals continued confinement in a secure prison with little opportunity for treatment and fewer privileges.
Landmark decision
Landmark court decisions establish new precedents that establish a significant new legal principle or concept, or otherwise substantially change the interpretation of existing law...
of the U.S. Supreme Court that determined a state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
violated due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
by involuntarily committing
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
a criminal defendant for an indefinite period of time solely on the basis of his permanent incompetency to stand trial
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
on the charges filed against him.
Background
In general, if a defendant is found incompetent to proceed to trial the criminal proceedings are suspended. In those cases where the charges are petty, the charges are often dropped or a plea bargainPlea bargain
A plea bargain is an agreement in a criminal case whereby the prosecutor offers the defendant the opportunity to plead guilty, usually to a lesser charge or to the original criminal charge with a recommendation of a lighter than the maximum sentence.A plea bargain allows criminal defendants to...
may be made in which the charges are nolle prossed if the defendant agrees to seek treatment. Otherwise, the defendant is usually committed to a psychiatric hospital
Psychiatric hospital
Psychiatric hospitals, also known as mental hospitals, are hospitals specializing in the treatment of serious mental disorders. Psychiatric hospitals vary widely in their size and grading. Some hospitals may specialise only in short-term or outpatient therapy for low-risk patients...
for treatment until the defendant is restored to competency, at which point the trial will proceed.
Circumstances
Theon Jackson, a deaf-muteDeaf-mute
For "deafness", see hearing impairment. For "Deaf" as a cultural term, see Deaf culture. For "inability to speak", see muteness.Deaf-mute is a term which was used historically to identify a person who was both deaf and could not speak...
who could not read, write or communicate in other ways, was charged with two counts of petty theft. Competency evaluations
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
and testimony
Testimony
In law and in religion, testimony is a solemn attestation as to the truth of a matter. All testimonies should be well thought out and truthful. It was the custom in Ancient Rome for the men to place their right hand on a Bible when taking an oath...
by the evaluating doctors showed that Jackson's intelligence was too low for him to understand the nature of the charges against him, even if he were able to develop the ability to communicate, and that the prognosis for restoration of competency was "rather dim" even if he were not a deaf mute. Despite testimony that the state of Indiana
Indiana
Indiana is a US state, admitted to the United States as the 19th on December 11, 1816. It is located in the Midwestern United States and Great Lakes Region. With 6,483,802 residents, the state is ranked 15th in population and 16th in population density. Indiana is ranked 38th in land area and is...
had no facilities to treat Jackson's problems, Jackson was committed
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
to a psychiatric hospital
Psychiatric hospital
Psychiatric hospitals, also known as mental hospitals, are hospitals specializing in the treatment of serious mental disorders. Psychiatric hospitals vary widely in their size and grading. Some hospitals may specialise only in short-term or outpatient therapy for low-risk patients...
for treatment.
Appeals
Jackson filed a motion for a new trial. This was denied.Appealing on a writ of certiorari
Writ
In common law, a writ is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court...
to the Supreme Court of Indiana, the petitioner Jackson argued that his commitment was equal to a "life sentence" even though he had not been convicted of a crime. The petitioner claimed he was being denied equal protection because, without the criminal charges pending against him, the State would have been required to proceed using Indiana's statutory provisions for the feeble-minded
Feeble-minded
The term feeble-minded was used from the late nineteenth century in Great Britain, Europe and the United States to refer to a specific type of "mental deficiency". At the time, mental deficiency was an umbrella term, which encompassed all degrees of educational and social deficiency...
or for the mentally ill. Under these provisions Jackson would have been entitled to greater rights. He also claimed that what was essentially an indefinite commitment deprived him of due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
and subjected him to cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
. However, the State Supreme Court affirmed the denial of the lower court. A rehearing was also denied. The U.S. Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Ruling
The Supreme Court reversed. It held that the state of Indiana cannot constitutionally commit the petitioner for an indefinite period of time on the sole grounds that he was incompetent to stand trial on the charges filed against him, thus violating both the equal protection and due processDue process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
clauses of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
The Court examined Indiana procedure of pretrial commitment of incompetent criminal defendant as set forth in Ind. Ann. Stat. 9-1706a and compared it with the procedures for committing persons who are "feeble-minded
Feeble-minded
The term feeble-minded was used from the late nineteenth century in Great Britain, Europe and the United States to refer to a specific type of "mental deficiency". At the time, mental deficiency was an umbrella term, which encompassed all degrees of educational and social deficiency...
, and are therefore unable properly to care for themselves" and those for the "mentally ill". The Court found the procedures were essentially similar with one important difference. A person committed as "feeble-minded" may be released "at any time" his condition warrants it in the judgment of the superintendent of the institution. A person committed as "mentally ill" may be released when the superintendent of the institution discharges him, or when he is cured. Committing the criminal defendant indefinitely violates equal protection.
Therefore, the Court ruled that Indiana's indefinite commitment of a criminal defendant solely because he lacks the capacity to stand trial violates due process.
The Court declined to rule on the issue of the pending charges themselves, reasoning that the issue of petitioner's criminal responsibility at the time of the alleged offenses has not yet been adjudicated, and therefore it would be premature for the Court to dismiss the charges against petitioner.
Significance
Before this landmark case, pre-trial involuntary commitmentInvoluntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
of incompetent
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
individuals often meant lengthy or even lifetime confinement in a maximum security institution with little concern for treatment. This was true even though they were neither tried for or convicted of a crime. In this case, the Court for the first time put limits on the length of time an incompetent person may be confined. However, the court offers only general guidelines and by 1994, twenty years after the case, 32 states still had not enacted periodic judicial review of incompetent detainees. Many states still allowed a detention period that exceeded that maximum sentence that person would have received if convicted.
Further, by refusing to rule on the charges themselves, the court did not clarify the proper disposition of criminal charges pending against a person whose competency can not be restored. This means that in those states where the charges are not dismissed, the individual may not be converted to a civil status eligible for civil commitment, resulting in such an individuals continued confinement in a secure prison with little opportunity for treatment and fewer privileges.