State of Indiana v. William Coats
3 N.E.3d 528
| Ind. | 2014Background
- William Coats, age 67 with Alzheimer’s/dementia, was charged with class D felony sexual battery (granddaughter as alleged victim).
- Court-ordered exam by two experts concluded Coats was not competent to stand trial and unlikely or unable to be restored to competency.
- Trial court found Coats incompetent and that he could not be restored, and denied the State’s motion to commit him to the Division of Mental Health and Addiction (DMHA) for restoration services.
- The State appealed interlocutorily, arguing Ind. Code § 35-36-3-1(b) mandates commitment to DMHA when a defendant is found incompetent.
- The Court of Appeals split; the Indiana Supreme Court granted transfer to resolve whether the trial court had discretion to refuse commitment where it found restoration impossible.
- The Supreme Court held the statutory language unambiguously requires commitment to DMHA after a finding of incompetency and remanded with an order to commit Coats.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Coats) | Held |
|---|---|---|---|
| Whether trial court may refuse to commit a defendant to DMHA after finding the defendant not competent to stand trial | Trial court lacks discretion; Ind. Code § 35-36-3-1(b) unambiguously requires commitment to DMHA for restoration services | Once a court finds a defendant cannot be restored, due process and equal protection forbid commitment for futile restoration | Court: Trial court has no discretion; statute requires commitment to DMHA after finding of incompetency and the DMHA superintendent, not the trial court, determines whether restoration is substantially probable |
| Whether Jackson v. Indiana bars commitment where trial court finds restoration impossible | N/A | Relies on Jackson to argue limit on detention without periodic review and on finding of futility | Court: Jackson inapplicable because statute provides a 90-day institutional review, avoiding Jackson’s due-process defect |
| Whether Davis and Curtis support refusing commitment when court-appointed experts predict no restoration | N/A | Argues Davis and Curtis require dismissal when restoration is impossible; commitment implies a finding of restoration probability | Court: Davis and Curtis require a proper finding that restoration is impossible, but that finding is statutorily committed to DMHA, not the trial court |
Key Cases Cited
- Jackson v. Indiana, 406 U.S. 715 (U.S. 1972) (due process limits duration of commitment absent a substantial-probability finding)
- State v. Davis, 898 N.E.2d 281 (Ind. 2008) (dismissal appropriate where it is apparent defendant will never attain competency and confinement would be fundamentally unfair)
- Curtis v. State, 948 N.E.2d 1143 (Ind. 2011) (emphasizes statutory procedures; a finding that restoration is impossible must be properly made under the statutory scheme)