State of Louisiana v. Glenn Cook
226 So. 3d 387
| La. | 2017Background
- Respondent (56) was found not guilty by reason of insanity in 1986 for attempted aggravated rape and committed to inpatient psychiatric treatment.
- He was later released to supervised group homes (1999, 2004, 2016) but has a history of relapses and intermittent hospitalizations; treatment records show ongoing supervision and medication compliance.
- Respondent filed a motion in the original criminal district court seeking relief from sex-offender registration; the district court granted relief.
- The State (Attorney General) moved to rescind, arguing La. R.S. 15:544.1 requires civil petitions challenging registration to be filed in the 19th J.D.C.; the district court refused to rescind, finding the statutory venue/procedure inapplicable because respondent was an insanity acquittee, not a convict.
- The Louisiana Supreme Court granted writs and held the statutory definitions bring insanity acquittees who were committed within the sex-offender registration law’s scope; it vacated the district court’s relief and required challenges to be filed under La. R.S. 15:544.1 in the 19th J.D.C.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether persons found not guilty by reason of insanity and committed must register under La. R.S. 15:540 et seq. | Respondent: insanity acquittal is not a conviction; statute’s registration duty applies only to convicted persons. | State: statutory definition of “conviction or other disposition adverse to the subject” includes insanity acquittees who were committed; thus they must register. | Court: Held registration law’s definition includes insanity acquittees who were committed; respondent must follow registration law. |
| Whether challenges to registration by such persons must be filed under La. R.S. 15:544.1 in the 19th J.D.C. | Respondent: 15:544.1 applies to convicted offenders only; district court was proper forum. | State: 15:544.1 governs petitions challenging registration "as they apply to a particular offender convicted of or adjudicated delinquent for a sex offense," and statutory scheme encompasses insanity acquittees by definition. | Court: Held petitioner must seek relief under La. R.S. 15:544.1 in the 19th J.D.C.; district court erred. |
| Proper interpretation of defined term “conviction or other disposition adverse to the subject” in La. R.S. 15:541(7) | Respondent: definitions section shouldn’t change the plain meaning of “convicted” in operative provisions; ordinary meaning excludes insanity acquittal. | State: Definition expressly treats acquittal by reason of insanity with commitment as an ‘‘adverse disposition’’ for registration purposes. | Court: Held the statutory definition controls; read together with legislative purpose, it includes committed insanity acquittees. |
| Whether rule of lenity or plain-language canon requires narrower reading exempting insanity acquittees | Respondent: plain text of operative registration provisions contemplates conviction; lenity and ordinary meaning counsel exemption. | State: scheme is civil/regulatory with public-safety purpose; ambiguity resolved by definition and purpose; lenity inapplicable. | Court: Held statute is civil and remedial; legislative purpose and express definition resolve any ambiguity against exemption; lenity not applied. |
Key Cases Cited
- State v. Branch, 759 So.2d 31 (La. 2000) (explains that an insanity acquittal reflects that defendant committed the act but lacked criminal responsibility)
- Jones v. United States, 463 U.S. 354 (U.S. 1983) (insanity acquittal establishes commission of criminal act due to mental illness)
- State v. Clark, 117 So.3d 1246 (La. 2013) (sex-offender registration law should be read to effectuate public-safety purpose)
- State v. Piazza, 596 So.2d 817 (La. 1992) (legislative intent governs statutory interpretation)
- State ex rel. Olivieri v. State, 779 So.2d 735 (La. 2001) (characterizes registration scheme as remedial/public-safety rather than punitive)