406 U.S. 715, 92 S. Ct. 1845, 32 L. Ed. 2d 435 (1972)
Theon Jackson is a mentally defective deaf mute with a mental level of a pre-school child.1
He cannot read, write, or otherwise communicate except through limited sign language.2 In May 1968, at age 27, he was charged in the Criminal Court of Marion County, Indiana, with separate robberies of two women that had occurred the preceding July, involving property valued at four dollars and five dollars respectively.3
As the statute requires, the court appointed two psychiatrists to examine Jackson. A competency hearing was subsequently held at which petitioner was represented by counsel.4 At the hearing, the court received the doctors' joint report concluding that Jackson was unable to understand the nature of the charges or participate in his defense due to his communication skills, hearing loss, and mental deficiency.5 The doctors testified that it was extremely unlikely Jackson could ever develop the necessary skills, and the interpreter testified that Indiana had no facilities that could help someone in Jackson's condition.6
The trial court found that Jackson lacked comprehension sufficient to make his defense and ordered him committed to the Indiana Department of Mental Health until certified sane.7 Jackson's counsel filed a motion for a new trial arguing that the commitment amounted to a life sentence without conviction and deprived him of constitutional rights, but the trial court denied the motion.8 The Supreme Court of Indiana affirmed the denial.9 The United States Supreme Court granted certiorari.10 By the time of the Supreme Court's consideration, Jackson had been confined for three and one-half years on the basis of the incompetency finding.11
Whether Indiana deprived Jackson of equal protection of the laws by committing him under the incompetency statute's standards and release conditions rather than the standards applicable under the statutes for commitment of feeble-minded or mentally ill persons?12
The Equal Protection Clause of the Fourteenth Amendment prohibits a state from subjecting a criminal defendant to a more lenient standard for commitment.13 It also prohibits a more stringent standard for release than those generally applicable to other citizens not charged with offenses.14 The pendency of criminal charges does not justify such differential treatment.15
Yes. The evidence established little likelihood of improvement in Jackson's condition, rendering his commitment under the incompetency statute effectively permanent.16 Under the feeble-minded or mentally ill statutes he might be eligible for release when his condition justified it or when he no longer required custodial care.17 The pending criminal charges do not provide a greater justification for different treatment than conviction and sentence.18
Indiana deprived Jackson of equal protection of the laws under the Fourteenth Amendment.19
Whether Indiana's indefinite commitment of Jackson solely on account of his incompetency to stand trial violated the Due Process Clause of the Fourteenth Amendment?20
Due process requires that the nature and duration of commitment bear a reasonable relation to the purpose for which the individual is committed.21 A person charged with a criminal offense who is committed solely on account of his incapacity to proceed to trial cannot be held more than the reasonable period of time necessary to determine whether there is a substantial probability that he will attain that capacity in the foreseeable future.22
Yes. The record established no substantial probability that Jackson would ever attain competency to stand trial.23 The examining physicians testified that it was extremely unlikely he could develop the necessary communication skills, and the interpreter confirmed that no state facilities could help him.24 He had already been confined for three and one-half years without any progress toward that goal.25
Indiana's indefinite commitment of Jackson violated the Due Process Clause of the Fourteenth Amendment.26
Whether the criminal charges against Jackson should be dismissed on grounds of fundamental fairness given the length of his commitment and his inability to stand trial?27
Fundamental fairness may require dismissal of charges against an incompetent accused on grounds such as the Sixth Amendment right to a speedy trial or the denial of due process inherent in holding pending criminal charges indefinitely over the head of one who will never have a chance to prove his innocence.28 However, the issue must be ripe for decision.29
No. The issue is not sufficiently ripe for ultimate decision.30 Criminal responsibility at the time of the alleged offenses is distinct from competency to stand trial.31 The state courts should have the first opportunity to determine these issues in light of the holdings on equal protection and due process.32
The question whether the criminal charges against Jackson should be dismissed is not sufficiently ripe for decision by the Court at this time.33