State of Indiana v. William Coats, 2013 Ind. App. LEXIS 57

The State charged Coats, born in 1943, with Class D felony sexual battery against his granddaughter.
Coats has Alzheimer’s/dementia; two doctors diagnosed dementia and believed there was little chance of restoration to competency.
The trial court found Coats incompetent and not likely to become competent, but denied the State’s request to commit him to DMHA.
The State filed a written request to commit Coats under IC 35-36-3-1; Coats moved to dismiss arguing it would violate his rights if never restorable.
At subsequent hearings, the court again denied commitment; the State sought interlocutory appeal which was accepted.
The appellate court ultimately held that, given progressive dementia and no probability of restoration, commitment procedures were not required to be followed to achieve restoration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly denied commitment to DMHA for restoration services	State argues the statute requires commitment after incompetency	Coats argues continued commitment would violate due process and equal protection	Yes; denial affirmed; competency restoration would be ineffective due to progressive dementia

Curtis v. State, 948 N.E.2d 1143 (Ind. 2011) (balances state interests with restoration prospects; cannot realize if not restorable)
Jackson v. Indiana, 406 U.S. 715 (U.S. 1972) (no long-term commitment for non-restorable defendant; periodic review required)
Davis v. State, 898 N.E.2d 281 (Ind. 2008) (commitment focuses on restoration and rapid disposition of charges)
State v. J.S., 987 N.E.2d 831 (Ind. Ct. App. 2010) (juvenile context; emphasizes care, protection, treatment, rehabilitation)
Strunk v. United States, 412 U.S. 434 (U.S. 1973) (state interests in disposition of charges; related to competency procedures)
Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (due process considerations in commitment decisions)