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Law School Case Brief

Baxstrom v. Herold - 383 U.S. 107, 86 S. Ct. 760 (1966)


Equal protection does not require that all persons be dealt with identically, but it does require that a distinction made have some relevance to the purpose for which the classification is made. 


Petitioner Johnnie K. Baxstrom, while a prisoner, was certified as insane by a prison physician and transferred to Dannemora State Hospital, an institution under the jurisdiction of the New York Department of Corrections and used for prisoners declared mentally ill while serving sentence. Dannemora's director filed a petition in the state Surrogate's Court stating that Baxstrom's sentence was expiring and requesting that he be civilly committed under § 384 of the N. Y. Correction Law. At the proceeding, the State submitted medical evidence that Baxstrom was still mentally ill and in need of hospital care. The Surrogate stated that he had no objection to Baxstrom's transfer to a civil hospital under the jurisdiction of the Department of Mental Hygiene, but that under § 384 that decision was up to the latter Department. That Department had determined ex parte that Baxstrom was not suitable for care in a civil hospital. When Baxstrom's sentence expired his custody shifted to the Department of Mental Hygiene but he remained at Dannemora. Baxstrom's petitions for writs of habeas corpus in state courts were dismissed and Baxstrom's request that he be transferred to a civil hospital was denied as beyond the court's power. The Supreme Court of the United states granted Baxstrom's petition for certiorari.


Was Baxstrom denied equal protection when he was denied the jury review that was available to others in the state who were civilly committed?




The Supreme Court of the United States held that Baxstrom was denied equal protection of the laws by the statutory procedure under which a person could be civilly committed at the expiration of his penal sentence without the jury review that was available to all other persons who were civilly committed in the state, and by his civil commitment to the institution beyond the expiration of his prison term without a judicial determination that he was dangerously mentally ill under N.Y. Mental Hyg. Law § 74.

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