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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. Justice has finally been served. So glad that Dr. Ley can finally sleep peacefully at night knowing the truth has finally come to the surface.

  2. While this right is guaranteed by our Constitution, it has in recent years been hampered by insurance companies, i.e.; the practice of the plaintiff's own insurance company intervening in an action and filing a lien against any proceeds paid to their insured. In essence, causing an additional financial hurdle for a plaintiff to overcome at trial in terms of overall award. In a very real sense an injured party in exercise of their right to trial by jury may be the only party in a cause that would end up with zero compensation.

  3. Why in the world would someone need a person to correct a transcript when a realtime court reporter could provide them with a transcript (rough draft) immediately?

  4. This article proved very enlightening. Right ahead of sitting the LSAT for the first time, I felt a sense of relief that a score of 141 was admitted to an Indiana Law School and did well under unique circumstances. While my GPA is currently 3.91 I fear standardized testing and hope that I too will get a good enough grade for acceptance here at home. Thanks so much for this informative post.

  5. No, Ron Drake is not running against incumbent Larry Bucshon. That’s totally wrong; and destructively misleading to say anything like that. All political candidates, including me in the 8th district, are facing voters, not incumbents. You should not firewall away any of voters’ options. We need them all now more than ever. Right? Y’all have for decades given the Ds and Rs free 24/7/365 coverage of taxpayer-supported promotion at the expense of all alternatives. That’s plenty of head-start, money-in-the-pocket advantage for parties and people that don’t need any more free immunities, powers, privileges and money denied all others. Now it’s time to play fair and let voters know that there are, in fact, options. Much, much better, and not-corrupt options. Liberty or Bust! Andy Horning Libertarian for IN08 USA House of Representatives Freedom, Indiana

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