Law School Case Brief
Jones v. United States - 463 U.S. 354, 103 S. Ct. 3043 (1983)
Within 50 days of commitment, a criminal defendant acquitted by reason of insanity 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. D.C. Code Ann. § 24-301(d)(2). 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. D.C. Code Ann. § 24-301(e). 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.
Under the District of Columbia Code, a criminal defendant could be acquitted by reason of insanity if his insanity was affirmatively established by a preponderance of the evidence. He was to be then committed to a mental hospital, and within 50 days thereafter, was entitled to a judicial hearing to determine his eligibility for release, at which he had the burden of proving by a preponderance of the evidence that he was no longer mentally ill or dangerous. The code also provided that the acquittee was entitled to a judicial hearing every six months at which he could establish by a preponderance of the evidence that he was entitled to release. Petitioner Jones 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 Jones 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 Jones 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 the lower court.
Having been hospitalized for more than one year, was Jones entitled to be released unconditionally, or alternatively, be recommitted pursuant to the civil-commitment procedures under the District of Columbia Code?
The Supreme Court of the United States held that when Jones established by a preponderance of the evidence that he was not guilty of a crime by reason of insanity, the Constitution 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. There was no correlation between severity of the offense and length of time necessary for recovery. Because automatic commitment under D.C. Code Ann. § 24-301(d)(1) followed only if an acquittee advanced the insanity defense and proved that his criminal act was a product of his mental illness, there was diminished risk of commitment for mere idiosyncratic behavior. The preponderance of the evidence standard comported with due process.
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