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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. Frankly, it is tragic that you are even considering going to an expensive, unaccredited "law school." It is extremely difficult to get a job with a degree from a real school. If you are going to make the investment of time, money, and tears into law school, it should not be to a place that won't actually enable you to practice law when you graduate.

  2. As a lawyer who grew up in Fort Wayne (but went to a real law school), it is not that hard to find a mentor in the legal community without your school's assistance. One does not need to pay tens of thousands of dollars to go to an unaccredited legal diploma mill to get a mentor. Having a mentor means precisely nothing if you cannot get a job upon graduation, and considering that the legal job market is utterly terrible, these students from Indiana Tech are going to be adrift after graduation.

  3. 700,000 to 800,000 Americans are arrested for marijuana possession each year in the US. Do we need a new justice center if we decriminalize marijuana by having the City Council enact a $100 fine for marijuana possession and have the money go towards road repair?

  4. I am sorry to hear this.

  5. I tried a case in Judge Barker's court many years ago and I recall it vividly as a highlight of my career. I don't get in federal court very often but found myself back there again last Summer. We had both aged a bit but I must say she was just as I had remembered her. Authoritative, organized and yes, human ...with a good sense of humor. I also appreciated that even though we were dealing with difficult criminal cases, she treated my clients with dignity and understanding. My clients certainly respected her. Thanks for this nice article. Congratulations to Judge Barker for reaching another milestone in a remarkable career.

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