Laurie A. Beal v. State of Maine
151 A.3d 502
| Me. | 2016Background
- In 2005 Laurie A. Beal was found not criminally responsible by reason of mental disease or defect and committed to custody of the Commissioner of the Department of Health and Human Services (DHHS).
- In October 2015 Beal, then hospitalized at Riverview Psychiatric Center, petitioned for a full discharge from DHHS custody under 15 M.R.S. § 104-A.
- A January 2016 hearing included testimony from Beal, family, Riverview treating clinicians, the Director of the State Forensic Service, and Beal’s own psychological examiner; multiple written psychiatric and neuropsychological reports were in the record.
- Trial court found Beal still suffers a mental disease or defect rendering her dangerous to herself, others, and property, and denied discharge.
- Beal appealed, arguing the court erred in finding she currently has a qualifying mental disease or defect; the State defended the denial.
- The Supreme Judicial Court considered whether the evidence compelled a contrary finding and affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Beal bears burden to prove by clear and convincing evidence she may be discharged without likelihood of causing injury due to mental disease or defect | Beal sought discharge and argued she no longer has a mental disease or defect causing dangerousness | State argued Beal failed to prove by clear and convincing evidence that discharge would be safe | Beal bears the burden; evidence did not compel finding she is free of qualifying mental disease or defect; petition denied |
| Standard of review for existence of a "mental disease or defect" | Beal argued the court should review de novo | State argued factual review for clear error applies because term is legal but determination is factual | Court held factual review applies; will affirm unless evidence compels contrary finding |
| Proper legal definition of "mental disease or defect" for discharge inquiry | Beal urged that her behaviors are situational and not from a qualifying condition | State relied on statutory/Criminal Code definition that it means severe abnormal conditions grossly impairing perception of reality | Court applied the Criminal Code definition (severely abnormal conditions that grossly and demonstrably impair perception/understanding of reality) |
| Whether court erred in questioning witnesses about community supports | Beal contended such questioning prejudiced her case | State pointed to Beal’s own testimony about supports and need for services | Court found no error; questioning was appropriate and not prejudicial |
Key Cases Cited
- Taylor v. Comm’r of Mental Health & Mental Retardation, 481 A.2d 139 (Me. 1984) (clarifies burden—clear and convincing—on insanity acquittee seeking discharge)
- Green v. Comm’r of Mental Health & Mental Retardation, 750 A.2d 1265 (Me. 2000) (addresses use of Criminal Code definition of "mental disease or defect" and standard of review)
- Roberts v. Comm’r of Mental Health & Mental Retardation, 562 A.2d 680 (Me. 1989) (holds determination of "mental disease or defect" is a legal concept for court but factual and reviewable for clear error)
- In re Fleming, 431 A.2d 616 (Me. 1981) (explains medical conclusions are not determinative of statutory standard)