Transfer of a prisoner diagnosed with schizophrenia to a state psychiatric hospital is not an involuntary commitment under state law. The Supreme Court of Wyoming affirmed the transfer of a prisoner who had argued that the state's involuntary commitment statute should have been applied.
Vernon Page was serving time in a Wyoming prison for assault and burglary. Upon arriving at the prison he was tested and found to be suffering from the beginning stages of schizophrenia. While in prison, he began to exhibit increasingly bizarre behavior, and after being tested again, the prison psychiatrist diagnosed him as suffering from schizophrenia. The doctor believed that Page's behavior would make him vulnerable to attacks from his fellow prisoners, and that the prison did not have the facilities necessary to protect and treat him. The psychiatrist recommended that Page be transferred to a state psychiatric hospital. The prison warden, following the doctor's recommendation, initiated transfer proceedings.
At the hearing, the only evidence presented was the testimony of the prison psychiatrist. Based on this testimony, the court found Page to be a danger to himself and others and that the prison could not adequately treat his mental illness. Thus, the court held that transfer would be appropriate, and it granted the warden's petition. Page appealed.
The Supreme Court of Wyoming affirmed. Page argued that since he could be incarcerated in the state hospital even after the expiration of his prison term, he could only be transferred under the state's involuntary commitment statute. The court disagreed, pointing to the testimony of the prison psychiatrist that while Page's schizophrenia was incurable, with proper treatment he could be released into the community at the end of his sentence.