Monday, December 23, 2013

Jackson v. Indiana case brief

Jackson v. Indiana case brief summary
406 U.S. 715 (1972)

Defendant, a mentally impaired deaf mute, sought review of an order of the Supreme Court of Indiana, which affirmed a trial court's decision to deny defendant's motion for new trial after defendant was committed to the Indiana Department of Mental Health pursuant to Ind. Stat. Ann. § 9-1706a (Supp. 1971) (recodified at Ind. Code 35-5-3-2 (1971)) on grounds that defendant lacked sufficient comprehension to make his defense.

The defendant contended that his commitment under Ind. Stat. Ann. § 9-1706a mounted to a life sentence, and deprived him of equal protection because absent the criminal charges against him, the state would have had to proceed under the civil commitment procedures of Ind. Stat. Ann. §§ 22-1907a, 22-1209.


  • The Court held that defendant's commitment under Ind. Stat. Ann. §9-1706a deprived defendant of equal protection and violated his due process rights under the Fourteenth Amendment. 
  • Defendant's commitment deprived him of equal protection because §9-1706a subjected him to a more lenient commitment standard and to a more stringent standard of release than those generally applicable to all others not charged with criminal offenses. 
  • In effect, §9-1706a condemned defendant to permanent institutionalization without the showing required for commitment, or the opportunity for release, afforded by Ind. Stat. Ann. §§ 22-1209 and 22-1907. 
  • Defendant's commitment violated his due process rights because the nature and duration of defendant's commitment did not bear a reasonable relation to the purpose for which he was committed.

The Court reversed defendant's commitment to a mental facility and remanded for consideration of whether fundamental fairness required that the charges against defendant be dismissed.

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