Under Florida law, when a criminal defendant has been found mentally incompetent to stand trial, involuntarily committed and later released, the committing courts do not have jurisdiction to determine whether or not the committee should remain hospitalized. Such a decision rests solely in the hands of the hospital administrator.
Michael John Heidrick was a defendant who was adjudicated incompetent to stand trial. He was involuntarily hospitalized. Five years later, the circuit court entered an order, pursuant to Jackson v. Indiana, 406 U.S. 715 (1972) and the Florida Rules of Criminal Procedure, finding that there was no substantial probability that Heidrick would become competent to stand trial and that he met the criteria for involuntary placement. The circuit courts dismissed Heidrick's charges without prejudice to the state and committed him to the Department of Health and Rehabilitative Services (HRS).
Upon notice of the dismissal, the state moved to have the committing courts determine whether or not Heidrick should remain involuntarily committed. The committing courts entered an order holding that they had no jurisdiction to make such a determination and the state filed petitions in the appellate court.
What Heidrick Means
The hospital administrator, not the committing court, determines the fate of a criminal defendant who has been found incompetent to stand trial and involuntarily to a state hospital. The court lacks jurisdiction to determine whether or not to continue involuntary commitment.
The District Court of Appeals of Florida for the Third District sitting en banc, held that the state was wrong in its contention that the committing courts had jurisdiction to determine involuntary commitment. In Jackson, the court held, a defendant who is found mentally incompetent to stand trial and involuntarily committed is protected by the 14th amendment in that indefinite commitment (without a separate civil hearing) is a due process violation. Further, the court held, Florida criminal procedure mandates that if, after five years, no substantial probability of becoming competent to stand trial exists, the court shall dismiss the charges against the defendant and commit the defendant to the HRS. The applicable discharge procedures under the law, the court held, defer commitment determinations to the hospital administrator, not the committing court. The state's petitions therefore, were denied.
