Ex parte Remus

27 Ohio N.P. (n.s.) 16, 1928 Ohio Misc. LEXIS 1147
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedJanuary 6, 1928
StatusPublished

This text of 27 Ohio N.P. (n.s.) 16 (Ex parte Remus) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte Remus, 27 Ohio N.P. (n.s.) 16, 1928 Ohio Misc. LEXIS 1147 (Ohio Super. Ct. 1928).

Opinion

Bell, J.

This cause came on for hearing upon a petition for a writ of habeas corpus, the amended return of the Sheriff, the reply and the evidence.

The question for determination is the legality of the detention of George Remus by William Anderson, the Sheriff of Hamilton county.

The petition alleges that Remus is unlawfully restrained [17]*17of his liberty by the said Anderson, Sheriff, and prays for his discharge from the claimed unlawful restraint.

The return of the Sheriff sets forth that Remus is restrained by virtue of a commitment issued by the Probate Court of this county, the pertinent part of which reads as follows:

“All the proceedings prescribed by law to entitle George Remus to be admitted in the Lima State Hospital having been had, you are commanded forthwith to take charge of and convey the said George Remus to the hospital at Lima, Ohio.”

The reply to the return of the Sheriff sets forth that the Probate Court was without authority to make such an order; that the order is void, and that the Sheriff of Hamilton county has no legal authority to hold the said Remus.

The evidence adduced consists of certified copies of the report of certain physicians appointed by -the court to examine Remus, the opinion of the court finding Remus to be now insane, and the order committing him to the Lima State Hospital, and a paper entitled “Inquest of Lunacy.”

It is conceded that the Probate Court had jurisdiction of the subject matter under inquiry and of the person of Remus, but it is contended by counsel for Remus that the Probate Court had no jurisdiction to make this order of commitment, it being claimed that certain jurisdictional prerequisites were lacking.

Counsel for the Sheriff contends that the case is disposed of by Section 12165, General Code, which reads as follows:

“When Writ Not Alloioed. If it appears that the person alleged to be restrained of his liberty is in custody of an officer under process issued by a court or magistrate, or by virtue of the judgment or order of a court of record, and that the court or magistrate had jurisdiction to issue the process, render the judgment, or make the order, the writ shall not be allowed; or, if the jurisdiction appears after the writ is allowed, the person shall not be discharged by reason of any informality or defect in the process, judgment, or order.”

The contention of counsel for the Sheriff being that the Probate Court having general jurisdiction over insanity-[18]*18matters, and in this case having jurisdiction over Rémus the writ must be denied.

This position, in the opinion of the court, is untenable, is not supported by the authorities, nor the statute. The decisions of the courts of last resort are uniform in holding that even though a court has jurisdiction of the person and the subject matter under inquiry, if it makes an order or enters á judgment without legal authority which deprives a person of liberty, the legality of the order or judgment will be determined on habeas corpus.

12 Ruling Case Law, 1196.
People, ex rel. Tweed, v. Liscomb, 60 N. Y., 559.
Craig v. Hecht, 263 U. S., 255.
Hans Neilson, Petitioner, 131 U. S., 176.
Ex Parte Creasy, 243 Mo., 679.
In Re Mills, 135 U. S., 263.

The legislature of Ohio by Section 12165 of the General Code above quoted has written into the statute law of this state this well recognized principle.

It is therefore the duty of this court to determine whether or not the- Probate Court had jurisdiction to make the order committing'Remus to the Lima State Hospital.

Remus was tried in this court for the murder of his wife Imogene Remus. The killing took place on the 6th day of October, 1927, and the defendant Remus interposed the defense that he was insane at the time of the killing. The jury trying that cause acquitted Remus on the sole ground of insanity. By their verdict and the legal presumption attaching thereto the status of Remus was fixed as an insane person and the burden of proving that he was sane at any date subsequent to October 6, 1927, was.upon Remus. By virtue of this verdict and the statutes of- this state the clerk of this court Certified the finding of the jury to the Probate Court. A hearing was had by the Probaté Court, and as the result of the hearing that court made the order which is in question in this case.

It is claimed by counsel for Remus that section 1956, General Code, had application to the proceedings in the Probate Court and that that section makes it a jurisdictional prerequisite to the making of an .order of commitment that in addition to the finding of the Probate Court [19]*19that the person being examined is insane, there must be a certificate of two medical witnesses in attendance; that there is no such certificate, and that without said certificate the Probate Court was without jurisdiction to order the commitment of Remus to the Lima State Hospital; that the commitment is void, and that Remus should be discharged.

This brings us to a consideration of the question — Does Section 1956, General Code, have application to proceedings in the Probate Court where a defendant has been acquited of crime upon the sole ground of insanity?

A brief examination of the history of the statutes with reference to insane persons will be helpful in the dtermination of this question. Prior to the year 1906 all insane persons in Ohio were confined in seven state institutions located at Cleveland, Columbus, Toledo, Dayton, Athens, Massillon and Cincinnati, which were provided for in Chapter 7, Sections 1947 to 1983, both inclusive, and Sections 7240 to 7243 of the General Code. Section 1956, General Code, which is the basis of the claim of Remus to be discharged, is found in Chapter 7, and reads as follows:

“Court Shall Have Certificate of Two Medical Witnesses. — Unless for good cause the investigation is adjourned, the judge, at the time appointed, shall proceed to examine the witnesses in attendance.' Upon the’hearing of the testimony, if he is satisfied that the person charged is insane, he shall ..cause a certificate to be made out by two medical witnesses in attendance that the person is insane to the best of their knowledge and belief. The medical witnesses must have at least fivé years experience in the practice of medicine, shall not be related, by blood or marriage, to the person alleged to be insane, or to the person making the application for commitment, nor have any official connection with any state hospital. The medical certificate shall contain answers to such interrogatories as the Ohio Board of Administration, with the advice of the superintendents of the several hospitals prescribes.”

In 1906’the legislature passed an-act’ providing -for- the establishment of a state hospital for the criminal insane to be located at Lima, Ohio, and known as Lima State Hospital, and porvided in the act the procedure for their [20]*20incarceration. The act as originally passed is found in 98 Ohio Laws at page 236.

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Related

Nielsen
131 U.S. 176 (Supreme Court, 1889)
In Re Mills
135 U.S. 263 (Supreme Court, 1890)
Craig v. Hecht
263 U.S. 255 (Supreme Court, 1923)
People Ex Rel. Tweed v. . Liscomb
60 N.Y. 559 (New York Court of Appeals, 1875)
Ex parte Creasy
148 S.W. 914 (Supreme Court of Missouri, 1912)

Cite This Page — Counsel Stack

Bluebook (online)
27 Ohio N.P. (n.s.) 16, 1928 Ohio Misc. LEXIS 1147, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-remus-ohctcomplhamilt-1928.