State v. Coats, 24 N.E.3d 528

William Coats (age 67, diagnosed with Alzheimer’s/dementia) was charged with class D felony sexual battery and requested a competency determination.
Court-appointed psychiatrist and psychologist each evaluated Coats (~1 hour) and concluded he was not competent to stand trial; both reported little or no likelihood of restoration.
The trial court found Coats not competent and also found he could not be restored, but denied the State’s motion to commit him to the Division of Mental Health and Addiction (DMHA).
The State sought interlocutory review of the trial court’s refusal to commit; the Court of Appeals affirmed in a split decision, and the Indiana Supreme Court granted transfer.
The core statutory scheme is Ind. Code ch. 35-36-3: trial courts determine present competency and must commit defendants found not competent to the DMHA, which has 90 days to certify whether there is a substantial probability the defendant can be restored.

Issue	Plaintiff's Argument (Coats)	Defendant's Argument (State)	Held
Whether a trial court may refuse to commit a defendant to DMHA after finding the defendant not competent and unable to be restored	Trial court may refuse; detaining after a finding of no restoration violates due process and equal protection (futile detention)	Statute unambiguously requires commitment to DMHA whenever the court finds the defendant currently lacks competency	Trial courts have no discretion under Ind. Code §35-36-3-1(b); they must commit a defendant found not competent to DMHA for restoration services
Whether Jackson, Davis, Curtis bar commitment when trial court believes restoration is impossible	Coats: Jackson/Davis/Curtis support that charges cannot be held if restoration is impossible	State: Those cases do not preclude commitment under the statutory procedure; proper finding of impossibility is for DMHA, not the trial court	Jackson does not apply given statutory safeguards; Davis/Curtis show only that a proper finding of impossibility ends State interest — that finding must be made by the DMHA superintendent after commitment

Jackson v. Indiana, 406 U.S. 715 (1972) (precommitment detention limited to reasonable time to determine probability of restoration)
State v. Davis, 898 N.E.2d 281 (Ind. 2008) (commitment justified by State interest in restoration; dismissal required where hospitalization exceeds maximum sentence and State offers no countervailing interest)
Curtis v. State, 948 N.E.2d 1143 (Ind. 2011) (statutory procedures control competency determinations; a finding that restoration is impossible must follow the statutory process and determination by appropriate authority)