Facts:
Mr. Jackson, the Appellate, was a mentally deficient deaf. He wasn’t able to read, write or communicate. The Appellate was charged with robbery of two different women. Appellant robbed the women for four and five dollars respectively. Appellant was found to be incompetent to stand trial at an incompetency hearing. The Court ordered Appellant to be committed until he was competent to stand trial.
Issue:
Was the Appellant’s Constitutional rights violated?
Did Indiana’s pre-trial commitment violate the Appellant’s equal protection rights by committing him on a more stringent stand than other civil commitment proceedings?
Was the Appellant’s due process rights were
violated based on his indefinite commitment based solely on his inability to stand trial?
Reasoning:
The Appellant was subject to a more lenient commitment standard but a more stringent standard for released from commitment than others not charged with an offense and consequently violated the Appellant’s rights to equal protection.
A person charged by a State with a criminal offense who is committed solely on account of his incapacity to proceed to trial cannot be held more than the reasonable period of time necessary to determine whether there is a substantial probability that he will reach the capacity in the foreseeable future.
If it is determined that a defendant will never be deemed competent to stand trial, the State must either institute the customary civil commitment proceeding that would be required to commit indefinitely any other citizen or release the defendant.
Holding:
Reversed and Remanded