SCDDSN v. Linkhorn
27684
S.C.Nov 16, 2016Background
- Rocky A. Linkhorn was arrested on sexual-offense charges; the circuit court found him incompetent to stand trial and unlikely to regain competency.
- The circuit court ordered the solicitor to initiate judicial-admission (involuntary commitment) proceedings in probate court to commit Linkhorn to the Department of Disabilities and Special Needs (DDSN).
- Before the probate court decided whether Linkhorn was intellectually disabled, the solicitor moved in circuit court for a rule to show cause compelling DDSN to admit and house Linkhorn and to bar DDSN from refusing similar involuntary commitments; the circuit court granted the motion.
- Linkhorn’s cognitive deficits were caused by an anoxic brain injury sustained at age 23; his disability manifested after the developmental period.
- DDSN appealed, arguing the circuit court used the wrong statutory definition of “intellectual disability” for involuntary commitment under the Act (Title 44, Chapter 20).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which statutory definition of “intellectual disability” governs involuntary commitment to DDSN after a finding of unfitness to stand trial? | (Solicitor/Respondents) The broader Chapter 23 definition of “person with intellectual disability” applies (no age limit), so DDSN must accept defendants like Linkhorn. | (DDSN/Appellant) The narrower Act definition in Chapter 20 applies (requires manifestation during the developmental period and related disabilities before age 22); therefore DDSN may refuse involuntary commitment for conditions arising after developmental period. | The Court held Chapter 20’s definition controls for involuntary commitment to DDSN; because Linkhorn’s condition manifested after the developmental period (and related-disability age limit), involuntary commitment under the Act is unavailable. |
Key Cases Cited
- Hodges v. Rainey, 341 S.C. 79, 533 S.E.2d 578 (2000) (plain statutory language controls judicial interpretation)
- Futch v. McAllister Towing of Georgetown, Inc., 335 S.C. 598, 518 S.E.2d 591 (1999) (court need not reach additional issues when a dispositive issue resolves the appeal)