Friday, November 15, 2013

Foucha v. Louisiana case brief

Foucha v. Louisiana case brief summary
504 U.S. 71 (1992)


CASE SYNOPSIS
Petitioner sought review of a decision of the Supreme Court of Louisiana affirming the denial of petitioner's release from a mental institution. The institutionalization resulted from a previous action in which petitioner was found not guilty of criminal actions by reason of insanity.

CASE FACTS
Petitioner was acquitted of criminal charges by reason of insanity and committed to a mental institution for an indefinite period of time. After several years, it was recommended that petitioner be discharged or released. A release panel determined petitioner was no longer mentally ill.

PROCEDURAL HISTORY
The trial court appointed a sanity commission that was unable to certify whether petitioner would be a menace to society. The trial court denied petitioner's release and the district court and state supreme court affirmed.

DISCUSSION

  • On appeal, the U.S. Supreme Court reversed and remanded, reasoning petitioner's rights under the Due Process Clause, U.S. Constitutional amendment XIV, were violated. 
  • The Court reasoned petitioner could only be detained as long as he was mentally ill or posed a danger to society. 
  • The Court held the prosecution failed to establish by clear and convincing evidence that petitioner was a danger to society and, therefore, he was entitled to release.

CONCLUSION

Judgment of the lower court reversed, because the prosecution failed to meet its burden of proving petitioner was a danger to society and the period of time during which petitioner could be held in a mental institution was measured by whether or not he was mentally ill or dangerous.

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