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At the least, Due Process requires that the nature and duration of commitment bear some reasonable relation to the purpose for which the individual is committed.
The Indiana procedure for pretrial commitment of incompetent criminal defendants provides that a trial judge with reasonable ground to believe the defendant is incompetent to stand trial must appoint two examining physicians and schedule a competency hearing, at which the defendant may introduce evidence. If the court, on the basis of the physicians' report and "other evidence," finds that the defendant lacks "comprehension sufficient to understand the proceedings and make his defense," the trial is delayed and the defendant is remanded to the state department of mental health for commitment to an "appropriate psychiatric institution" until defendant shall become "sane." Other statutory provisions apply to commitment of citizens who are "feeble-minded, and are therefore unable properly to care for themselves." The procedures for committing such persons are substantially similar to those for determining a criminal defendant's pretrial competency, but 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. Indiana also has a comprehensive commitment scheme for the "mentally ill," such as those with a "psychiatric disorder" as defined by the statute, who can be committed on a showing of mental illness and need for "care, treatment, training or detention." A person so committed may be released when the superintendent of the institution shall discharge him, or when he is cured.
Petitioner Theon Jackson, a mentally defective deaf mute, who could not read, write, or virtually otherwise communicate, was charged with two criminal offenses and committed under the Indiana procedure. The doctors' report showed that Jackson's condition precluded his understanding of the nature of the charges against him or participating in his defense and their testimony showed that the prognosis was "rather dim;" that even if Jackson were not a deaf mute he would be incompetent to stand trial; and that Jackson's intelligence was not sufficient to enable him ever to develop the necessary communication skills. According to a deaf-school interpreter's testimony, the State had no facilities that could help Jackson learn minimal communication skills. After finding that Jackson lacked comprehension sufficient to make his defense, the court ordered Jackson be committed until such time as the health department could certify his sanity to the court. Jackson's counsel filed a motion for a new trial, which was denied. The state supreme court affirmed the denial. Contending that his commitment was tantamount to a "life sentence" without his having been convicted of a crime, Jackson claimed that commitment under Indiana law deprived him of equal protection because, absent the criminal charges against him, the State would have had to proceed under the other statutory procedures for the feeble-minded or those for the mentally ill, under either of which Jackson would have been entitled to substantially greater rights. Jackson also asserted that indefinite commitment under the section deprived him of due process and subjected him to cruel and unusual punishment.
Did Jackson's commitment to the Indiana Department of Mental Health pursuant to Ind. Stat. Ann. § 9-1706a deprive Jackson of equal protection and violate his due process rights under the Fourteenth Amendment?
The Supreme Court of the United States held that Jackson's commitment under Indiana law deprived him of equal protection and violated his due process rights under the Fourteenth Amendment. Jackson's commitment deprived him of equal protection because the law subjected him to a more lenient commitment standard and to a more stringent standard of release than those generally applicable to all others not charged with criminal offenses. In effect, the law condemned Jackson to permanent institutionalization without the showing required for commitment, or the opportunity for release, afforded by Ind. Stat. Ann. §§ 22-1209 and 22-1907. The Court also held that Jackson's commitment violated his due process rights because the nature and duration of his commitment did not bear a reasonable relation to the purpose for which he was committed.