Jones v. United States (1983)
Encyclopedia
Jones v. United States, is a United States Supreme Court case in which the court, for the first time, addressed whether the United States Constitution
allows a defendant
, who has been found not guilty by reason of insanity (NGRI) of a misdemeanor
crime, to be involuntarily confined
to a mental institution until such time as he is no longer a danger to himself or others with few other criteria or procedures limiting the actions of the state.
of a crime by reason of insanity
(insanity acquittees) were subjected to commitment procedures to institutions for the "criminally insane" with little attention or oversight provided as to what these procedures were. In the early 1970s, the procedures began to be examined legally on constitutional as well as therapeutic grounds.
At that time, U.S. state
jurisdictions had varying criteria and procedures governing this situation. In some states, insanity acquittees were governed by the same rules and procedures as an individual facing civil commitment. Another group of states, although treating insanity acquittees in a generally similar fashion as the civilly committed, had more stringent criteria governing insanity acquittees; for example, in emergency commitment proceedings in which a civilly committed person may be committed for a maximum of one week, an insanity acquittee may be committed on an emergency basis for 90 days—and then the discharge would take place only after judicial approval. A third group subjected an insanity acquittee to automatic, indefinite commitment, usually with periodic reviews to determine if commitment continued to be necessary.
, a misdemeanor
, for attempting to steal a jacket
from a Washington D.C. department store. Upon arraignment
in the District of Columbia Superior Court, the judge ordered a competency evaluation
at St. Elizabeth's Hospital. The competency report to the court was that Jones suffered from paranoid schizophrenia, but that he was competent
to proceed to trial. Eventually, Jones plead not guilty by reason of insanity to the misdemeanor offense which carried a one year maximum sentence; the prosecution did not contest the plea
and Jones was automatically committed to St. Elizabeth's Hospital for a minimum of 50 days.
Upon his first release hearing in May 1976, his request for release was denied. In his second release hearing held in February 1977, his request for either release or civil commitment was also denied, despite the contention of Jones' counsel that his cumulative hospitalization exceeded the maximum penalty of a one year incarceration for the crime. For the government's case, a psychologist
from St. Elizabeth's Hospital testified that, in the opinion of the hospital's staff, Jones continued to actively suffer from paranoid schizophrenia and therefore remained a danger to himself and others.
who affirmed the lower court's decision, although three judges dissented. The case was appealed to the Supreme Court.
The second issue was the proportionality of the commitment compared to Jones' hypothetical maximum sentence had he been imprisoned; that is, does the maximum sentence provide a constitutional limit for Jones' commitment? Although three judges at the District Court level had agreed that the constitution does provide such a limit, the Supreme Court rejected this line of thinking. Writing for the majority, Powell argued that different considerations go into the choosing of a sentence than those underlying a commitment of an insanity acquittee. He argued against the idea that indefinite commitment amounted to punishment.
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
allows a defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
, who has been found not guilty by reason of insanity (NGRI) of a misdemeanor
Misdemeanor
A misdemeanor is a "lesser" criminal act in many common law legal systems. Misdemeanors are generally punished much less severely than felonies, but theoretically more so than administrative infractions and regulatory offences...
crime, to be involuntarily confined
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
to a mental institution until such time as he is no longer a danger to himself or others with few other criteria or procedures limiting the actions of the state.
Background
Historically, those persons acquittedAcquittal
In the common law tradition, an acquittal formally certifies the accused is free from the charge of an offense, as far as the criminal law is concerned. This is so even where the prosecution is abandoned nolle prosequi...
of a crime by reason of insanity
Insanity
Insanity, craziness or madness is a spectrum of behaviors characterized by certain abnormal mental or behavioral patterns. Insanity may manifest as violations of societal norms, including becoming a danger to themselves and others, though not all such acts are considered insanity...
(insanity acquittees) were subjected to commitment procedures to institutions for the "criminally insane" with little attention or oversight provided as to what these procedures were. In the early 1970s, the procedures began to be examined legally on constitutional as well as therapeutic grounds.
At that time, U.S. state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
jurisdictions had varying criteria and procedures governing this situation. In some states, insanity acquittees were governed by the same rules and procedures as an individual facing civil commitment. Another group of states, although treating insanity acquittees in a generally similar fashion as the civilly committed, had more stringent criteria governing insanity acquittees; for example, in emergency commitment proceedings in which a civilly committed person may be committed for a maximum of one week, an insanity acquittee may be committed on an emergency basis for 90 days—and then the discharge would take place only after judicial approval. A third group subjected an insanity acquittee to automatic, indefinite commitment, usually with periodic reviews to determine if commitment continued to be necessary.
Facts of the case
On September 19, 1975, Michael Jones was charged with petit larcenyLarceny
Larceny is a crime involving the wrongful acquisition of the personal property of another person. It was an offence under the common law of England and became an offence in jurisdictions which incorporated the common law of England into their own law. It has been abolished in England and Wales,...
, a misdemeanor
Misdemeanor
A misdemeanor is a "lesser" criminal act in many common law legal systems. Misdemeanors are generally punished much less severely than felonies, but theoretically more so than administrative infractions and regulatory offences...
, for attempting to steal a jacket
Jacket
A jacket is a hip- or waist-length garment for the upper body. A jacket typically has sleeves, and fastens in the front. A jacket is generally lighter, tighter-fitting, and less insulating than a coat, which is outerwear...
from a Washington D.C. department store. Upon arraignment
Arraignment
Arraignment is a formal reading of a criminal complaint in the presence of the defendant to inform the defendant of the charges against him or her. In response to arraignment, the accused is expected to enter a plea...
in the District of Columbia Superior Court, the judge ordered a competency evaluation
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
at St. Elizabeth's Hospital. The competency report to the court was that Jones suffered from paranoid schizophrenia, but that he was competent
Competence (law)
In American law, competence concerns the mental capacity of an individual to participate in legal proceedings. Defendants that do not possess sufficient "competence" are usually excluded from criminal prosecution, while witnesses found not to possess requisite competence cannot testify...
to proceed to trial. Eventually, Jones plead not guilty by reason of insanity to the misdemeanor offense which carried a one year maximum sentence; the prosecution did not contest the plea
Plea
In legal terms, a plea is simply an answer to a claim made by someone in a civil or criminal case under common law using the adversary system. Colloquially, a plea has come to mean the assertion by a criminal defendant at arraignment, or otherwise in response to a criminal charge, whether that...
and Jones was automatically committed to St. Elizabeth's Hospital for a minimum of 50 days.
Upon his first release hearing in May 1976, his request for release was denied. In his second release hearing held in February 1977, his request for either release or civil commitment was also denied, despite the contention of Jones' counsel that his cumulative hospitalization exceeded the maximum penalty of a one year incarceration for the crime. For the government's case, a psychologist
Psychologist
Psychologist is a professional or academic title used by individuals who are either:* Clinical professionals who work with patients in a variety of therapeutic contexts .* Scientists conducting psychological research or teaching psychology in a college...
from St. Elizabeth's Hospital testified that, in the opinion of the hospital's staff, Jones continued to actively suffer from paranoid schizophrenia and therefore remained a danger to himself and others.
Appeals
The case was appealed to the District of Columbia Court of AppealsDistrict of Columbia Court of Appeals
The District of Columbia Court of Appeals is the highest court of the District of Columbia. Established by the United States Congress in 1970, it is equivalent to a state supreme court, except that its power derives from Article I of the U.S. Constitution rather than from the inherent sovereignty...
who affirmed the lower court's decision, although three judges dissented. The case was appealed to the Supreme Court.
Decision
The Supreme Court examined two issues. The first was whether there was a constitutional basis for the practice in most states, and the District of Columbia, of automatically committing insanity acquitees. The court found that there was. Justice Powell, writing for the court, said that Jones' verdict established that he committed the crime and that he did so because he was mentally ill by a preponderance of evidence. "Congress has determined that a criminal defendant found not guilty by reason of insanity in the District of Columbia should be committed indefinitely to a mental institution for treatment and the protection of society."The second issue was the proportionality of the commitment compared to Jones' hypothetical maximum sentence had he been imprisoned; that is, does the maximum sentence provide a constitutional limit for Jones' commitment? Although three judges at the District Court level had agreed that the constitution does provide such a limit, the Supreme Court rejected this line of thinking. Writing for the majority, Powell argued that different considerations go into the choosing of a sentence than those underlying a commitment of an insanity acquittee. He argued against the idea that indefinite commitment amounted to punishment.
Indefinite commitment of an insanity acquittee, based on proof of insanity by only a preponderance of the evidence, comports with due process. Addington v. TexasAddington v. TexasAddington v. Texas , , is a U.S. Supreme Court landmark case that set the standard for involuntary commitment for treatment by raising the burden of proof required to commit persons for psychiatric treatment from the usual civil burden of proof of "preponderance of the evidence" to "clear and...
, 441 U. S. 418, held that the government, in a civil commitment proceeding, must demonstrate by clear and convincing evidence that the individual is mentally ill and dangerous. However, the concerns critical to that decision—based on the risk of error that a person might be committed for mere "idiosyncratic behavior"—are diminished or absent in the case of insanity acquitees, and do not require the same standard of proof in both cases. Proof that the acquittee committed a criminal act as a result of mental illness eliminates the risk that he is being committed for mere idiosyncratic behavior.
See also
- List of United States Supreme Court cases, volume 463
- Jackson v. IndianaJackson v. IndianaJackson v. Indiana was a landmark decision of the U.S. Supreme Court that determined a state violated due process by involuntarily committing a criminal defendant for an indefinite period of time solely on the basis of his permanent incompetency to stand trial on the charges filed against...
- Foucha v. LouisianaFoucha v. LouisianaFoucha v. Louisiana, 504 U.S. 71 , was a U.S. Supreme Court case in which the court addressed the criteria for the continued commitment of an individual who had been found not guilty by reason of insanity...
- Addington v. TexasAddington v. TexasAddington v. Texas , , is a U.S. Supreme Court landmark case that set the standard for involuntary commitment for treatment by raising the burden of proof required to commit persons for psychiatric treatment from the usual civil burden of proof of "preponderance of the evidence" to "clear and...