463 U.S. 354 (1983), 81-5195, Jones v. U.s.
|Docket Nº:||No. 81-5195.|
|Citation:||463 U.S. 354, 103 S.Ct. 3043, 77 L.Ed.2d 694|
|Party Name:||Michael JONES, Petitioner, v. UNITED STATES.|
|Case Date:||June 29, 1983|
|Court:||United States Supreme Court|
Argued Nov. 2, 1982.
Mental hospital patient, who was committed following acquittal by reason of insanity, sought his release from the hospital. The Superior Court of the District of Columbia denied his request for immediate release. The District of Columbia Court of Appeals, 396 A.2d 183, affirmed, but on rehearing, 411 A.2d 624, his immediate release was ordered. On rehearing en banc, the Court of Appeals, 432 A.2d 364, again affirmed the Superior Court. Certiorari was granted. The Supreme Court, Justice Powell, held that when a criminal defendant established by a preponderance of the evidence that he was not guilty of a crime by reason of insanity, the due process clause permitted the Government, on the basis of the insanity judgment, to confine him to a mental institution until such time as he had regained his sanity or was no longer a danger to himself or society, and he could be confined to a mental hospital for a period longer than he could have been incarcerated had he been convicted.
Justice Brennan filed a dissenting opinion in which Justice Marshall and Justice Blackmun joined.
Justice Stevens filed a dissenting opinion.
[103 S.Ct. 3044] Syllabus[*]
Under the District of Columbia Code, a criminal defendant may be acquitted by reason of insanity if his insanity is affirmatively established by a preponderance of the evidence. He is then committed to a mental hospital and within 50 days thereafter is entitled to a judicial hearing to determine his eligibility for release, at which he has the burden of proving by a preponderance of the evidence that he is no longer mentally ill or dangerous. The Code also provides that the acquittee is entitled to a judicial hearing every six months at which he may establish by a preponderance of the evidence that he is entitled to release. Petitioner was charged in the District of Columbia Superior Court with attempted petit larceny, a misdemeanor punishable by a maximum prison sentence of one year. The Superior Court found petitioner not guilty by reason of insanity and committed him to a mental hospital. At his subsequent 50-day hearing, the court found that he was mentally ill and constituted a danger to himself or others. A second release hearing was held after petitioner had been hospitalized for more than one year, the maximum period he could have spent in prison if he had been convicted. On that basis he demanded that he be released unconditionally or recommitted pursuant to the civil-commitment procedures under the District of Columbia Code, including a jury trial and clear and convincing proof by the Government of his mental illness and dangerousness. The Superior Court denied his request for a civil-commitment hearing, reaffirmed the findings made at the 50-day hearing, and continued his commitment. The District of Columbia Court of Appeals ultimately affirmed.
Held: When a criminal defendant establishes by a preponderance of the evidence that he is not guilty of a crime by reason of insanity, the Constitution permits the Government, on the basis of the insanity judgment, to confine him to a mental institution until such time as he has regained his sanity or is no longer a danger to himself or society. Pp. 3048-3053.
(a) A verdict of not guilty by reason of insanity is sufficiently probative of mental illness and dangerousness to justify commitment of the acquittee for the purposes [103 S.Ct. 3045] of treatment and the protection of society. Such a verdict establishes that the defendant committed an act constituting a criminal offense, and that he committed the act because of mental
illness. It was not unreasonable for Congress to determine that these findings constitute an adequate basis for hospitalizing the acquittee as a dangerous and mentally ill person. The fact that a person has been found, beyond a reasonable doubt, to have committed a criminal act certainly indicates dangerousness. Nor is it unreasonable to conclude that an insanity acquittal supports an inference of continuing mental illness. The 50-day hearing assures that every acquittee has prompt opportunity to obtain release if he has recovered. Pp. 3049-3050.
(b) Indefinite commitment of an insanity acquittee, based on proof of insanity by only a preponderance of the evidence, comports with due process. Addington v. Texas, 441 U.S. 418, 99 S.Ct. 1804, 60 L.Ed.2d 323, held that the government in a civil-commitment proceeding must demonstrate by clear and convincing evidence that the individual is mentally ill and dangerous. However, the concerns critical to that decision--based on the risk of error that a person might be committed for mere "idiosyncratic behavior"--are diminished or absent in the case of insanity acquittees and do not require the same standard of proof in both cases. Proof that the acquittee committed a criminal act as a result of mental illness eliminates the risk that he is being committed for mere idiosyncratic behavior. P. 3051.
(c) An insanity acquittee is not entitled to his release merely because he has been hospitalized for a period longer than he could have been incarcerated if convicted. The length of a sentence for a particular criminal offense is based on a variety of considerations, including retribution, deterrence, and rehabilitation. However, because an insanity acquittee was not convicted, he may not be punished. The purpose of his commitment is to treat his mental illness and protect him and society from his potential dangerousness. There simply is no necessary correlation between the length of the acquittee's hypothetical criminal sentence and the length of time necessary for his recovery. Pp. 3051-3052.
432 A.2d 364 (D.C.App.1981), affirmed.
Silas J. Wasserstrom argued the cause for petitioner. With him on the briefs were William J. Mertens and A. Franklin Burgess, Jr.
Joshua I. Schwartz argued the cause for the United States. With him on the brief were Solicitor General Lee,
Assistant Attorney General Jensen, and Deputy Solicitor General Frey.*
* Briefs of amici curiae urging reversal were filed by Michael L. Burack, M. Carolyn Cox, Arthur B. Spitzer, and Charles S. Sims for the American Civil Liberties Union et al.; and by Joseph H. Rodriquez, Michael L. Perlin, Stanley C. Van Ness, and John J. Ensminger for the Department of the Public Advocate, Division of Mental Health Advocacy, State of New Jersey.
Robert B. Remar filed a brief for the Georgia Legal Services Program, Inc., asamicus curiae.
Silas J. Wasserstrom, Washington, D.C., for petitioner.
Joshua I. Schwartz, Washington, D.C., for respondent.
Justice POWELL delivered the opinionof the Court.
The question presented is whether petitioner, who was committed to a mental hospital upon being acquitted of a criminal offense by reason of insanity, must be released because he has been hospitalized for a period longer than he might have served in prison had he been convicted.
In the District of Columbia a criminal defendant may be acquitted by reason of insanity if his insanity is "affirmatively established by a preponderance of the evidence." D.C.Code § 24-301(j) (1981). 1 If he successfully invokes the insanity defense, he is committed to a mental hospital. § 24-301(d)(1). 2 The statute provides several [103 S.Ct. 3046] ways of obtaining
release. Within 50 days of commitment the acquittee is entitled to a judicial hearing to determine his eligibility for release, at which he has the burden of proving by a preponderance of the evidence that he is no longer mentally ill or dangerous. § 24-301(d)(2). 3 If he fails to meet this burden at the 50-day hearing, the committed acquittee subsequently may be released, with court approval, upon certification of his recovery by the hospital chief of service. § 24-301(e). 4
Alternatively, the acquittee is entitled to a judicial hearing every six months at which he may establish by a preponderance of the evidence that he is entitled to release. § 24-301(k). 5
Independent of its provision for the commitment of insanity acquittees, the District [103 S.Ct. 3047] of Columbia also has adopted a civil-commitment procedure, under which an individual may be committed upon clear and convincing proof by the Government
that he is mentally ill and likely to injure himself or others. § 21-545(b). 6 The individual may demand a jury in the civil-commitment proceeding. § 21-544. Once committed, a patient may be released at any time upon certification of recovery by the hospital chief of service. §§ 21-546, 21-548. Alternatively, the patient is entitled after the first 90 days, and subsequently at 6-month intervals, to request a judicial hearing at which he may gain his release by proving by a preponderance of the evidence that he is no longer mentally ill or dangerous. § 21-546, 21-547; see Dixon v. Jacobs, 138 U.S.App.D.C. 319, 328, 427 F.2d 589, 598 (1970).
On September 19, 1975, petitioner was arrested for attempting to steal a jacket from a department store. The next day he was arraigned in the District of Columbia Superior Court on a charge of attempted petit larceny, a misdemeanor punishable by a maximum prison sentence of one year. §§ 22-103, 22-2202. The court ordered petitioner committed to St. Elizabeths, a public hospital for the mentally ill, for a determination of his competency to stand trial. 7 On March 2, 1976, a hospital psychologist submitted a report to the court stating that petitioner was competent to stand trial, that petitioner suffered from "Schizophrenia, paranoid
type," and that petitioner's alleged offense was "the product of his mental disease." Record 51. The court ruled that petitioner was competent to stand...
To continue readingFREE SIGN UP