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Justices: Man with Alzheimer’s must be committed per statute

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Noting the trial court had the best of intentions when it did not order a man with Alzheimer’s disease committed, the Indiana Supreme Court pointed out the trial court had to order his commitment under Indiana Code 35-36-3-1(b) after he was found not competent to stand trial.

William Coats faces a charge of Class D felony sexual battery against his granddaughter. He was born in 1943 and has been diagnosed with Alzheimer’s disease. He was evaluated by a psychiatrist and psychologist who found he was not competent to stand trial. The two also opined there was little likelihood he would be able to be restored to competency.

After the trial court found Coats incompetent to stand trial, the state filed a written request to commit him to the Division of Mental Health and Addiction pursuant to I.C. 35-36-3-1(b). Coats filed a motion to dismiss the charge, arguing since he cannot be restored to competency, commitment would violate his due process and equal protection rights. The trial court denied both motions; the Indiana Court of Appeals affirmed the denial of the commitment, with Judge Patricia Riley dissenting.

Justice Steven David pointed out in State of Indiana v. William Coats, 49S02-1305-CR-328, that the language of I.C. 35-36-3-1-3, -3, and -4 is unambiguous. There are steps that must be followed in determining a defendant’s competency to stand trial. The statute does not give trial court discretion to refuse to commit a defendant once it determines that he or she is not competent to stand trial, David wrote.

The justices also rejected Coats’ claim that Jackson v. Indiana, 406 U.S. 715 (1972), State v. Davis, 898 N.E.2d 281 (Ind. 2008), and Curtis v. State, 948 N.E.2d 1143 (Ind. 2011), support his argument that he should have the charge against him dismissed.

“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,” David wrote. “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.”
 

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  1. As one of the many consumers affected by this breach, I found my bank data had been lifted and used to buy over $200 of various merchandise in New York. I did a pretty good job of tracing the purchases to stores around a college campus just from the info on my bank statement. Hm. Mr. Hill, I would like my $200 back! It doesn't belong to the state, in my opinion. Give it back to the consumers affected. I had to freeze my credit and take out data protection, order a new debit card and wait until it arrived. I deserve something for my trouble!

  2. Don't we have bigger issues to concern ourselves with?

  3. Anyone who takes the time to study disciplinary and bar admission cases in Indiana ... much of which is, as a matter of course and by intent, off the record, would have a very difficult time drawing lines that did not take into account things which are not supposed to matter, such as affiliations, associations, associates and the like. Justice Hoosier style is a far departure than what issues in most other parts of North America. (More like Central America, in fact.) See, e.g., http://www.theindianalawyer.com/indiana-attorney-illegally-practicing-in-florida-suspended-for-18-months/PARAMS/article/42200 When while the Indiana court system end the cruel practice of killing prophets of due process and those advocating for blind justice?

  4. Wouldn't this call for an investigation of Government corruption? Chief Justice Loretta Rush, wrote that the case warranted the high court’s review because the method the Indiana Court of Appeals used to reach its decision was “a significant departure from the law.” Specifically, David wrote that the appellate panel ruled after reweighing of the evidence, which is NOT permissible at the appellate level. **But yet, they look the other way while an innocent child was taken by a loving mother who did nothing wrong"

  5. Different rules for different folks....

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