People v. Masterson
2011 IL 110072
| Ill. | 2011Background
- Masterson challenges SDPA equal protection regarding access to independent psychiatric defense.
- SDPA and SVPA definitions of mental disorder are identical per Masterson I.
- SDPA requires two court-appointed psychiatrists; Masterson sought a third independent evaluator but was denied.
- SDPA is civil in nature yet requires proof beyond a reasonable doubt and affords counsel and a jury trial.
- SVPA applies to a limited set of violent sex offenses and provides different evaluator rules and procedures.
- Court concludes Masterson is not similarly situated to SVPA respondents and upholds SDPA framework.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| SDPA denial of independent psychiatrist violates equal protection. | Masterson: not similarly situated; denial of independent evaluator. | State: different groups; SDPA and SVPA distinguished. | Not upheld; no equal protection violation. |
| Are SDPA and SVPA defendants similarly situated for equal protection purposes? | Masterson: yes, same mental disorder definition warrants similar treatment. | State: different groups and purposes justify differences. | Not similarly situated; claim rejected. |
Key Cases Cited
- Masterson I, 207 Ill.2d 305 (2003) (definition of mental disorder read into SDPA for due process)
- Burns, 209 Ill.2d 551 (2004) (discharge procedures differ between SDPA and SVPA)
- Whitfield, 228 Ill.2d 502 (2007) (threshold similarity necessary for equal protection claims)
- Spurlock, 388 Ill. App.3d 365 (2009) (SDPA applicability to broad criminal charges)
- Lawton, 212 Ill.2d 285 (2004) (SDPA alternative to criminal prosecution; procedure distinct from SVPA)
- L.T.M., 214 Ill.2d 60 (2005) (equal protection threshold of similarly situated required)
- D.W., 214 Ill.2d 289 (2005) (similarly situated analysis under equal protection)