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The Rhode Island Supreme Court has reversed a Superior Court judge’s decision to deny a defendant’s request for discharge from detention orders of commitment filed in two underlying criminal matters.
Defendant Edward Mather, who was found incompetent to stand trial, was placed in an outpatient facility, LaBelle House Group Home. When the defendant petitioned for discharge from the detention order of commitment, Superior Court Judge Brian Van Couyghen denied the request, finding that G.L. §40.1-5.3-3(m) was not applicable to the defendant because his commitment to the outpatient facility did not constitute “detention” pursuant to that subsection.
But based on a review of the record, the Supreme Court found that Van Couyghen erroneously denied Mather’s petitions to discharge him from the outpatient facility.
“Notwithstanding the undisputed conclusion by Dr. [Christine] Montross that Mr. Mather’s competency to stand trial is nonrestorable prior to the dismissal of the charge of domestic assault by strangulation, the trial justice nevertheless ordered Mr. Mather’s continued commitment to the outpatient facility based on an erroneous conclusion that the commitment did not constitute detention within the meaning of §40.1-5.3-3(m),” Justice Melissa A. Long wrote for the court. “However, the focus on ‘detention’ was misplaced. The plain language of §40.1-5.3-3(m) authorizes only three possible dispositions for defendants who are subject to a commitment order, whether placed in an inpatient facility or at an outpatient facility. When reading §40.1-5.3-3 liberally to effectuate its purpose as a remedial statute, it is clear that defendants who are committed and placed at outpatient facilities pursuant to §40.1-5.3-3(i)(2) are subject to detention within the meaning of §40.1-5.3-3(m).”
Long said it was clear that Mather’s continued commitment “no longer bears a reasonable relationship to the purpose of his commitment under §40.1-5.3-3(i)(2). As a result, we reject the state’s attempt to distinguish [State v. Morin, 606 A.2d 681 (R.I. 1992)] on the basis that it involved a defendant who was confined in a hospital: Mr. Mather is clearly detained pursuant to §40.1-5.3-3, irrespective of his outpatient status. Based on the trial justice’s determination that Mr. Mather’s competency to stand trial is nonrestorable prior to the dismissal of the pending charges pursuant to subsection (j), the Supreme Court’s holding in Jackson [v. Indiana, 406 U.S. 715 (1972)] confirms that due process requires discharge from the detention orders of commitment thirty days after such determination.”
Accordingly, Long said, “we hold that where, as here, a defendant is found to be incompetent to stand trial and competency is nonrestorable prior to the statutory dismissal period contained in §40.1-5.3-3(j), the defendant is entitled to be discharged from detention under the order of commitment thirty days thereafter pursuant to §40.1-5.3-3(m).”
The 21-page decision is State v. Mather, Lawyers Weekly No. 60-050-24.
Click here to read the full text of the opinion.