''Jackson v. Indiana'', 406 U.S. 715 (1972), was a landmark decision of the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

that determined a

U.S. state In the United States, a state is a constituent political entity, of which there are 50. Bound together in a political union, each state holds governmental jurisdiction over a separate and defined geographic territory where it shares its sove ...

violated due process by involuntarily committing a

criminal defendant In court proceedings, a defendant is a person or object who is the party either accused of committing a crime in criminal prosecution or against whom some type of civil relief is being sought in a civil case. Terminology varies from one jurisdic ...

for an indefinite period of time solely on the basis of his permanent incompetency to stand trial 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 bargain 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 hospitals, also known as mental health hospitals, behavioral health hospitals, are hospitals or wards specializing in the treatment of severe mental disorders, such as schizophrenia, bipolar disorder, eating disorders, dissociat ...

for treatment until the defendant is restored to competency, at which point the trial will proceed.

Facts

Theon Jackson, a

deaf-mute Deaf-mute is a term which was used historically to identify a person who was either deaf and used sign language or both deaf and could not speak. The term continues to be used to refer to deaf people who cannot speak an oral language or have som ...

who could not read, write or communicate in other ways, was charged with two counts of robbery. Competency evaluations and

testimony In law and in religion, testimony is a solemn attestation as to the truth of a matter. Etymology The words "testimony" and "testify" both derive from the Latin word ''testis'', referring to the notion of a disinterested third-party witness. ...

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 () is a U.S. state in the Midwestern United States. It is the 38th-largest by area and the 17th-most populous of the 50 States. Its capital and largest city is Indianapolis. Indiana was admitted to the United States as the 19th s ...

had no facilities to treat Jackson's problems, Jackson was committed to a

for treatment..

Appeals

Jackson filed a motion for a new trial. This was denied. Appealing on a

writ of certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...

to the Supreme Court of Indiana, Indiana attorneys Frank Spencer and Robert Robinson argued on behalf of the petitioner Jackson that Jackson's commitment was equal to a "

life sentence Life imprisonment is any sentence of imprisonment for a crime under which convicted people are to remain in prison for the rest of their natural lives or indefinitely until pardoned, paroled, or otherwise commuted to a fixed term. Crimes fo ...

" even though he had not been convicted of a crime. They claimed that petitioner Jackson was being denied

equal protection The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "''nor shall any State ... deny to any person within its jurisdiction the equal ...

because, without the criminal charges pending against him, the State would have been required to proceed using Indiana's

statutory A statute is a formal written enactment of a legislative authority that governs the legal entities of a city, state, or country by way of consent. Typically, statutes command or prohibit something, or declare policy. Statutes are rules made by le ...

provisions for the

feeble-minded The term feeble-minded was used from the late 19th century in Europe, the United States and Australasia for disorders later referred to as illnesses or deficiencies of the mind. At the time, ''mental deficiency'' encompassed all degrees of educa ...

or for the

mentally ill A mental disorder, also referred to as a mental illness or psychiatric disorder, is a behavioral or mental pattern that causes significant distress or impairment of personal functioning. Such features may be persistent, relapsing and remitt ...

. Under these provisions Jackson would have been entitled to greater rights. They 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.

Ruling

The Supreme Court reversed. With Indiana attorney Robert Robinson present, arguments were presented by Indiana attorney Frank Spencer. 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

and due process 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 "

, and are therefore unable properly to care for themselves" and those for the "

". 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

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 commitment of incompetent individuals often meant lengthy or even lifetime confinement in a

maximum security Maximum Security may refer to: * Supermax, "control-unit" prisons, or units within prisons * Maximum Security (comics), a comic book miniseries published by Marvel Comics * ''Maximum Security'' (Tony MacAlpine album), 1987 * ''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 individual's continued confinement in a secure prison with little opportunity for treatment and fewer privileges.

Footnote citations

External links

* {{caselaw source , case = ''Jackson v. Indiana'', {{Ussc, 406, 715, 1972, el=no , findlaw =https://caselaw.findlaw.com/us-supreme-court/406/715.html , justia =https://supreme.justia.com/cases/federal/us/406/715/ , loc =http://cdn.loc.gov/service/ll/usrep/usrep406/usrep406715/usrep406715.pdf , oyez =https://www.oyez.org/cases/1971/70-5009
Sell v. U.S.: Involuntary Treatment Case or Catalyst for Change?
United States Supreme Court cases United States Supreme Court cases of the Burger Court United States civil commitment case law Mental health case law in the United States 1972 in United States case law