Evan Leedy v. State of Indiana
2013 Ind. App. LEXIS 597
| Ind. Ct. App. | 2013Background
- Defendant Evan Leedy charged with four felony OWI counts after a high-speed crash that killed his girlfriend and seriously injured another motorist; Leedy suffered a traumatic brain injury and was comatose for about a month.
- Court-ordered competency evaluations by two court-appointed experts concluded Leedy could not understand proceedings or assist counsel; experts differed on restorability (one pessimistic; one said cognitive rehab might restore competency in 1–2 years).
- DMHA and Logansport State Hospital witnesses testified Logansport could evaluate and attempt restoration, outsourcing services as needed; DMHA counsel acknowledged funding constraints for outpatient services.
- Trial court found Leedy incompetent under Ind. Code § 35-36-3-1(b) and ordered commitment to DMHA, then stayed the commitment pending briefing and interlocutory appeal.
- Leedy challenged the statute and the commitment as violating due process, arguing the statutory process is geared to mental illness and cannot adequately address traumatic brain injury cases where needed therapies may be unavailable.
- Court of Appeals reviewed de novo, concluded the statutory scheme delegates restorability determinations to DMHA and did not violate Due Process as applied to Leedy; affirmed the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether commitment to DMHA under Ind. Code § 35-36-3-1 violates due process as applied to a defendant incompetent from traumatic brain injury | Leedy: statute is unconstitutional as applied because DMHA/facilities are geared to mental illness and cannot provide required therapies; commitment thus unlawfully deprives liberty | State: statute provides a procedurally adequate scheme; restoration probability is for DMHA to determine and the trial court followed statutory procedure | Court: statute is constitutional as applied; commitment procedures were followed and restoration determinations are for DMHA after evaluation/services; affirmed |
| Whether trial court retains discretion not to commit an incompetent defendant when experts say restoration unlikely | Leedy: trial court could avoid commitment if DMHA cannot restore him or provide necessary services | State: once court finds incompetency, statute mandates commitment and DMHA determines restorability | Court: trial court correctly committed (and stayed pending appeal); statutory language requires commitment and DMHA assessment; the court may not substitute its judgment for DMHA |
Key Cases Cited
- Sloan v. State, 947 N.E.2d 917 (Ind. 2011) (standard of review and statutory interpretation principles)
- Ryan v. State, 900 N.E.2d 43 (Ind. Ct. App. 2009) (statutory interpretation—ordinary meaning of terms)
- Curtis v. State, 948 N.E.2d 1143 (Ind. 2011) (statutory scheme requires commitment to DMHA and delegates restorability determinations to DMHA)
- State v. Davis, 898 N.E.2d 281 (Ind. 2008) (commitment focuses on probability of restoration; due process constraints on indefinite commitment)
- State v. Coats, 981 N.E.2d 1273 (Ind. Ct. App. 2013) (contrasting panel holding trial court could decline commitment where restoration unlikely; noted for comparison and review by supreme court)