Background
Historically, those persons acquitted of a crime by reason of insanity (insanity acquittees) were subjected to commitment procedures to institutions for the "criminally insane" with little attention or oversight provided as to what these procedures were. In the early 1970s, the procedures began to be examined legally on constitutional as well as therapeutic grounds. [2]
In common law jurisdictions, an acquittal certifies that the accused is free from the charge of an offense, as far as the criminal law is concerned. This is so even where the prosecution is simply abandoned by the prosecution. The finality of an acquittal is dependent on the jurisdiction. In some countries, such as the United States, an acquittal operates to bar the retrial of the accused for the same offense, even if new evidence surfaces that further implicates the accused. The effect of an acquittal on criminal proceedings is the same whether it results from a jury verdict, or whether it results from the operation of some other rule that discharges the accused. In other countries, the prosecuting authority may appeal an acquittal similar to how a defendant may appeal a conviction.
Insanity, madness, and craziness are terms that describe a spectrum of individual and group behaviors that are characterized by certain abnormal mental or behavioral patterns. Insanity can be manifest as violations of societal norms, including a person or persons becoming a danger to themselves or to other people. Conceptually, mental insanity also is associated with the biological phenomenon of contagion as in the case of copycat suicides. In contemporary usage, the term insanity is an informal, un-scientific term denoting "mental instability"; thus, the term insanity defense is the legal definition of mental instability. In medicine, the general term psychosis is used to include the presence either of delusions or of hallucinations or both in a patient; and psychiatric illness is "psychopathology", not mental insanity.
At that time, U.S. state jurisdictions had varying criteria and procedures governing this situation. In some states, insanity acquittees were governed by the same rules and procedures as an individual facing civil commitment. Another group of states, although treating insanity acquittees in a generally similar fashion as the civilly committed, had more stringent criteria governing insanity acquittees; for example, in emergency commitment proceedings in which a civilly committed person may be committed for a maximum of one week, an insanity acquittee may be committed on an emergency basis for 90 days—and then the discharge would take place only after judicial approval. A third group subjected an insanity acquittee to automatic, indefinite commitment, usually with periodic reviews to determine if commitment continued to be necessary. [2]
In the United States, a state is a constituent political entity, of which there are currently 50. Bound together in a political union, each state holds governmental jurisdiction over a separate and defined geographic territory and shares its sovereignty with the federal government. Due to this shared sovereignty, Americans are citizens both of the federal republic and of the state in which they reside. State citizenship and residency are flexible, and no government approval is required to move between states, except for persons restricted by certain types of court orders. Four states use the term commonwealth rather than state in their full official names.
Facts of the case
On September 19, 1975, Michael Jones was charged with petit larceny, a misdemeanor, for attempting to steal a jacket from a Washington, D.C. department store. Upon arraignment in the District of Columbia Superior Court, the judge ordered a competency evaluation at St. Elizabeth's Hospital. The competency report to the court was that Jones suffered from paranoid schizophrenia, but that he was competent to proceed to trial. Eventually, Jones plead not guilty by reason of insanity to the misdemeanor offense, which carried a one year maximum sentence; the prosecution did not contest the plea and Jones was automatically committed to St. Elizabeth's for a minimum of 50 days. [1]
Larceny is a crime involving the unlawful taking of the personal property of another person or business. It was an offence under the common law of England and became an offence in jurisdictions which incorporated the common law of England into their own law, where in many cases it remains in force.
A misdemeanor is any "lesser" criminal act in some common law legal systems. Misdemeanors are generally punished less severely than felonies, but theoretically more so than administrative infractions and regulatory offences. Many misdemeanors are punished with monetary fines.
Washington, D.C., formally the District of Columbia and commonly referred to as Washington or D.C., is the capital of the United States. Founded after the American Revolution as the seat of government of the newly independent country, Washington was named after George Washington, first President of the United States and Founding Father. As the seat of the United States federal government and several international organizations, Washington is an important world political capital. The city is also one of the most visited cities in the world, with more than 20 million tourists annually.
Upon his first release hearing in May 1976, his request for release was denied. In his second release hearing held in February 1977, his request for either release or civil commitment was also denied, despite the contention of Jones' counsel that his cumulative hospitalization exceeded the maximum penalty of a one year incarceration for the crime. [2] For the government's case, a psychologist from St. Elizabeth's Hospital testified that, in the opinion of the hospital's staff, Jones continued to actively suffer from paranoid schizophrenia and therefore remained a danger to himself and others. [1]
A psychologist studies normal and abnormal mental states, cognitive, emotional, and social processes and behavior by observing, interpreting, and recording how individuals relate to one another and to their environments. To become a psychologist, a person often completes a graduate university degree in psychology, but in most jurisdictions, members of other behavioral professions can also evaluate, diagnose, treat, and study mental processes.
Appeals
The case was appealed to the District of Columbia Court of Appeals, which affirmed the lower court's decision, although three judges dissented. The case was then appealed to the Supreme Court.
The District of Columbia Court of Appeals is the highest court of the District of Columbia. Established in 1970, it is equivalent to a state supreme court, except that its authority is derived from the United States Congress rather than from the inherent sovereignty of the states. The court is located in the former District of Columbia City Hall building at Judiciary Square. The D.C. Court of Appeals should not be confused with the District's federal appellate court, the United States Court of Appeals for the District of Columbia Circuit. The D.C. Court of Appeals and the Superior Court of the District of Columbia comprise the District's local court system.
Decision
The Supreme Court examined two issues. The first was whether there was a constitutional basis for the practice in most states, and the District of Columbia, of automatically committing insanity acquitees. The court found that there was. Justice Powell, writing for the court, said that Jones' verdict established that he committed the crime and that he did so because he was mentally ill by a preponderance of evidence. "Congress has determined that a criminal defendant found not guilty by reason of insanity in the District of Columbia should be committed indefinitely to a mental institution for treatment and the protection of society." [1]
The second issue was the proportionality of the commitment compared to Jones' hypothetical maximum sentence had he been imprisoned; that is, does the maximum sentence provide a constitutional limit for Jones' commitment? Although three judges at the District Court level had agreed that the constitution does provide such a limit, the Supreme Court rejected this line of thinking. Writing for the majority, Powell argued that different considerations go into the choosing of a sentence than those underlying a commitment of an insanity acquittee. He argued against the idea that indefinite commitment amounted to punishment. [1]
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 (1979) 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 acquitees, 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. [1]
The insanity defense, also known as the mental disorder defense, is an affirmative defense by excuse in a criminal case, arguing that the defendant is not responsible for his or her actions due to an episodic or persistent psychiatric disease at the time of the criminal act. This is contrasted with an excuse of provocation, in which defendant is responsible, but the responsibility is lessened due to a temporary mental state. It is also contrasted with a finding that a defendant cannot stand trial in a criminal case because a mental disease prevents them from effectively assisting counsel, from a civil finding in trusts and estates where a will is nullified because it was made when a mental disorder prevented a testator from recognizing the natural objects of their bounty, and from involuntary civil commitment to a mental institution, when anyone is found to be gravely disabled or to be a danger to themselves or to others.
The M'Naghten rule is any variant of the 1840s jury instruction in a criminal case when there is a defense of insanity:
that every man is to be presumed to be sane, and ... that to establish a defence on the ground of insanity, it must be clearly proved that, at the time of the committing of the act, the party accused was labouring under such a defect of reason, from disease of the mind, as not to know the nature and quality of the act he was doing; or if he did know it, that he did not know he was doing what was wrong.
A summary offence is a crime in some common law jurisdictions that can be proceeded against summarily, without the right to a jury trial and/or indictment.
Forensic psychiatry is a sub-speciality of psychiatry and is related to criminology. It encompasses the interface between law and psychiatry. A forensic psychiatrist provides services – such as determination of competency to stand trial – to a court of law to facilitate the adjudicative process and provide treatment like medications and psychotherapy to criminals.
Some jurisdictions may commit certain types of dangerous sex offenders to state-run detention facilities following the completion of their sentence if that person has a "mental abnormality" or personality disorder that makes the person likely to engage in sexual offenses if not confined in a secure facility. In the United States, twenty states, the federal government, and the District of Columbia have a version of these commitment laws, which are referred to as "Sexually Violent Predator" (SVP) or "Sexually Dangerous Persons" laws.
Involuntary treatment refers to medical treatment undertaken without the consent of the person being treated. In almost all circumstances, involuntary treatment refers to psychiatric treatment administered despite an individual's objections. These are typically individuals who have been diagnosed with a mental disorder and are deemed by a court or by two doctors to be a danger to themselves or to others.
Clark v. Arizona, 548 U.S. 735 (2006), is a United States Supreme Court case in which the Court upheld the constitutionality of the insanity defense used by Arizona.
Panetti v. Quarterman, 551 U.S. 930 (2007), is a decision by the Supreme Court of the United States, ruling that criminal defendants sentenced to death may not be executed if they do not understand the reason for their imminent execution, and that once the state has set an execution date death-row inmates may litigate their competency to be executed in habeas corpus proceedings. This decision reaffirmed the Court's prior holdings in Ford v. Wainwright, and Stewart v. Martinez-Villareal.
Sell v. United States, 539 U.S. 166 (2003), is a landmark decision in which the United States Supreme Court imposed stringent limits on the right of a lower court to order the forcible administration of antipsychotic medication to a criminal defendant who had been determined to be incompetent to stand trial for the sole purpose of making them competent and able to be tried. Specifically, the court held that lower courts could do so only under limited circumstances in which specified criteria had been met. In the case of Charles Sell, since the lower court had failed to determine that all the appropriate criteria for court-ordered forcible treatment had been met, the order to forcibly medicate the defendant was reversed.
Florida State Hospital (FSH) is a hospital and psychiatric hospital in Chattahoochee, Florida. Established in 1876, it Florida's only state mental institution until 1947. It currently has a capacity of 1,042 patients. The hospital's current Administration Building is on the National Register of Historic Places.
In criminal law, a mitigating factor, also known as extenuating circumstances, is any information or evidence presented to the court regarding the defendant or the circumstances of the crime that might result in reduced charges or a lesser sentence. Unlike a legal defense, it cannot lead to the acquittal of the defendant. The opposite of a mitigating factor is an aggravating factor.
Kansas v. Hendricks, 521 U.S. 346 (1997), was a United States Supreme Court case in which the Court set forth procedures for the indefinite civil commitment of prisoners convicted of a sex offense whom the state deems dangerous due to a mental abnormality.
Foucha v. Louisiana, 504 U.S. 71 (1992), was a U.S. Supreme Court case in which the court addressed the criteria for the continued commitment of an individual who had been found not guilty by reason of insanity. The individual remained involuntarily confined on the justification that he was potentially dangerous even though he no longer suffered from the mental illness that served as a basis for his original commitment.
Jackson v. Indiana, 406 U.S. 715 (1972), was a landmark decision of the United States Supreme Court that determined a U.S. 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.
Frendak v. United States, 408 A.2d 364 is a landmark case in which District of Columbia Court of Appeals decided that a judge could not impose an insanity defense over the defendant's objections.
Addington v. Texas, 441 U.S. 418 (1979), was a landmark United States Supreme Court case that set the standard for involuntary commitment for treatment by raising the burden of proof required to commit persons for psychiatric treatment from the usual civil burden of proof of "preponderance of the evidence" to "clear and convincing evidence".
Archuleta v. Hedrick, 365 F.3d 644 was a pro se petition for a writ of habeas corpus filed in the U.S. Court of Appeals for the Eighth Circuit in October 2002, appealing the dismissal of a case brought by defendant Benjamin Archuleta. Archuleta had been found not guilty by reason of insanity of assault and subsequently ordered to be confined in a prison mental hospital by the United States District Court for the Western District of Missouri after his successful insanity defense, as he was evaluated by a psychiatrist as dangerous. His appeal challenged this confinement and "forced treatment", requested a withdrawal of his original insanity defense, and sought his unconditional release from custody.
United States federal laws governing offenders with mental diseases or defects provide for the evaluation and handling of defendants who are suspected of having mental diseases or defects. The laws were completely revamped by the Insanity Defense Reform Act of 1984 in the wake of the John Hinckley verdict.
The most outstanding feature in the United States is that verdicts in criminal cases must almost always be unanimous.
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 (inpatient) or in the community (outpatient).
