Jackson v. Indiana

Jackson v. Indiana, cited as 406 U.S. 715 (1972), is a case decided by a unanimous decision of the U.S. Supreme Court, which held that a state’s “indefinite commitment of a criminal defendant solely on account of his lack of capacity to stand trial violates due process” as protected by the Fourteenth Amendment to the U.S. Constitution. Further, the Court held that the “permanent institutionalization” of such persons “without the showing required for commitment or the opportunity for release afforded by ordinary civil commitment procedures” violates the Fourteenth Amendment’s equal protection clause. As such, the Court established that reasonable time limits must apply to the pretrial institutionalization of persons lacking mental capacity to stand trial.

Indiana state law called for incompetent criminal defendants to be committed to psychiatric institutions until such time as they were declared sane and remanded for trial. State law also contained separate procedures governing the commitment of “feeble-minded” and “mentally ill” persons, which required meeting more formidable criteria prior to institutionalization and afforded greater rights and privileges during commitment than were available to criminal defendants.

Theon Jackson, the petitioner in the case, was described by the court as “a mentally defective deaf mute with a mental level of a pre-school child.” Jackson could neither read, write, nor effectively communicate. He was charged with two counts of robbery in 1969 and was subsequently found incompetent to stand trial by an Indiana court. Although Jackson was unlikely to ever reach the threshold of mental competency, he was committed to a psychiatric institution until such time as he was able to stand trial. Jackson’s attorney, Frank Spencer, contended that this amounted to a life sentence in the absence of a criminal conviction, thereby violating Jackson’s due process and equal protection rights under the Fourteenth Amendment. The Indiana Supreme Court denied Jackson’s appeal and the U.S. Supreme Court subsequently granted certiorari (i.e., agreed to review this decision).

Based on the likelihood that Jackson’s mental condition would not improve, the Supreme Court declared that Jackson’s commitment was indefinite and, for practical purposes, permanent. The court compared this case to Baxstrom v. Herold (1966), which held that a state prisoner was denied equal protection when he was civilly committed without the benefit of an otherwise generally available jury trial. With respect to Jackson, the Court reasoned that in the absence of pending criminal charges, he would have been subject to the legal commitment procedures for “feeble-minded” and “mentally ill” persons applicable to other citizens. Since these statutes afforded more favorable rights with regard to commitment, treatment, and release, Jackson’s permanent institutionalization without the benefit of these rights constituted a deprivation of equal protection.

[Page 528]Likewise, the Court held that “due process requires that the nature and duration of commitment bear some reasonable relation to the purpose for which the individual is committed.” Jackson’s commitment proceedings addressed only his current capacity to stand trial rather than his potential mental competency in the future, his ability to function in society, or the public interest in involuntary commitment. With regard to a criminal defendant who is involuntarily committed solely on the basis of an incapacity to stand trial, the Court held that the duration of institutionalization must be limited to a reasonable period of time required to determine the potential of attaining mental capacity in the foreseeable future. If such potential is deemed unlikely, the state must release the defendant or afford him the procedural due process rights afforded other citizens facing indefinite institutionalization under alternative civil commitment procedures. Even if a defendant is likely to be able to stand trial at some future date, he or she must make demonstrable progress in treatment to justify continuous commitment.

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