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Law School Case Brief

State v. Williams - 2010-Ohio-2453, 126 Ohio St. 3d 65, 930 N.E.2d 770


The procedures in R.C. 2945.39 and its related statutes that are less favorable to the person facing commitment than are the provisions governing a probate court commitment under R.C. Chapter 5122 are rationally related to legitimate government interests. Consequently, R.C. 2945.39 withstands equal-protection scrutiny. 


Thonex Williams was indicted in Ohio common pleas court for rape and other offenses. He was hospitalized when he was found to be incompetent to stand trial. After the time period prescribed by R.C. 2945.38 passed, the court retained jurisdiction under R.C. 2945.39(A)(2) and ordered Williams to remain hospitalized. On appeal, the Second District Court of Appeals of Ohio reversed the order and ruled that R.C. 2945.39 was unconstitutional. The State of Ohio appealed.


Was Williams' involuntary commitment under R.C. 2945.39 unconstitutional?




The state supreme court found that R.C. 2945.39 was a civil statute. Consequently, Williams need not have been afforded the constitutional rights afforded to a defendant in a criminal prosecution. In addition, the court held that Williams' involuntary commitment under R.C. 2945.39 did not violate equal-protection provisions. Finally, Williams' involuntary commitment under R.C. 2945.39 did not violate principles of due process. Therefore, Williams' continued involuntary commitment was appropriate as R.C. 2945.39 was constitutional.

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