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Tuesday, February 18, 2014
Ind. Decisions - Supreme Court decides one today
In State of Indiana v. William Coats, a 12-page, 5-0 opinion, Justice David writes:
Following his arrest for class D felony sexual battery, sixty-seven-year-old William Coats filed a motion for a competency determination. Doctors evaluating Coats diagnosed him with dementia, concluded he was not competent to stand trial, and predicted he could not be restored to competency. Based on the doctors’ reports, the trial court found that Coats was not competent to stand trial and that Coats could not be restored to competency. Subsequently, the State moved to commit Coats to the Division of Mental Health and Addiction (“DMHA”) pursuant to Ind. Code chapter 35-36-3, Indiana’s Comprehension to Stand Trial statutes. The trial court denied the State’s motion, and this interlocutory appeal ensued. Because we hold that Ind. Code § 35-36-3-1(b) requires trial courts to commit defendants found not competent to stand trial to the DMHA for competency restoration services, we remand this case to the trial court with an order to commit Coats to the DMHA. * * *
In all likelihood, the trial court here was motivated by the probability that Coats, at the time nearly seventy years old and suffering from Alzheimer’s disease, is unlikely to ever be competent to stand trial. Although the trial court had the best of intentions, it was bound to follow Ind. Code chapter 35-36-3 and had no discretion to substitute its determination as to whether Coats would eventually attain competency for that of the superintendent of the state institution where he should have been committed. Only by following the strict statutory framework set forth by the legislature in Ind. Code chapter 35-36-3 can both the interests of the State and Coats be protected.
Conclusion. We therefore remand this case to the trial court with an order to commit Coats to the DMHA for competency restoration services.
Dickson, C.J., Rucker, Massa, and Rush, J.J., concur.
Posted by Marcia Oddi on February 18, 2014 01:32 PM
Posted to Ind. Sup.Ct. Decisions