Reynolds v. Neill

381 F. Supp. 1374, 1974 U.S. Dist. LEXIS 6913
CourtDistrict Court, N.D. Texas
DecidedSeptember 4, 1974
DocketCA 3-74-91-B
StatusPublished
Cited by10 cases

This text of 381 F. Supp. 1374 (Reynolds v. Neill) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reynolds v. Neill, 381 F. Supp. 1374, 1974 U.S. Dist. LEXIS 6913 (N.D. Tex. 1974).

Opinion

OPINION OF THE COURT

Before GOLDBERG, Circuit Judge, and HUGHES and MAHON, District Judges.

PER CURIAM:

Petitioner Perry Wayne Reynolds filed a petition for a writ of habeas corpus in Texas state criminal district court on October 11, 1972. He alleged denial of both due process and equal protection in several aspects of his con *1376 finement at Rusk State Mental Hospital following acquittal of criminal charges pending against him. 1 The petition was denied, and the denial affirmed by the Court of Criminal Appeals of Texas. He then filed the petition in federal district court, alleging claims for relief on the basis of 28 U.S.C. § 2241 et seq., 42 U.S.C. § 1983, and 28 U.S.C. § 2201. A three judge court was also requested pursuant to 28 U.S.C. § 2281.

In a pre-trial order dated April 18, 1974, the issue of the constitutionality of Article 46.02 of the Vernon’s Ann. Texas Code of Criminal Procedure was severed from the other issues in the case, and a three judge court was convened to decide the issue. Arguments were heard on June 7th, 1974.

Perry Wayne Reynolds was indicted by a grand jury in Dallas County on the charge of murder with malice on March 29th, 1968. In May of that year, Reynolds entered an affidavit alleging insanity at the time of the commission of the offense, and further stated that he was insane at the time of trial. The affidavit was accompanied by a motion to try the issue of Reynold’s sanity prior to the trial on the merits. With the approval of the State’s Attorney this was done, and the jury found that the defendant was both insane at the time the criminal act was committed, and that he was insane at the time of trial. The jury recommended his commitment to a mental hospital until he became sane.

Since that time, Reynolds has been confined at Rusk State Mental Hospital, the only place in the state of Texas where persons acquitted of crimes are placed upon determination of present mental insanity. It is stated by Petitioner, and not disputed by Respondent, that Reynolds has little chance of making substantial progress in reaching a level of sanity as prescribed by the jury to be the condition for his release.

At issue in this case are the standards for commitment, treatment, and release as set out under Article 46.02 of the Texas Code of Criminal Procedure. This is the statute which provides for the procedure by which a defendant in a criminal case may have his present sanity tried either in advance of a trial on the merits, or during such trial. The defense in bar of insanity at the. time of offense may also be tried under this statute. Petitioner compares the procedures and standards of Art. 46.02 to those which apply to civilly committed persons under Vernon’s Ann.Civ.St. Texas Mental Health Code, Article 5547, and to facilitate discussion of Petitioner’s allegations, the procedures and standards under each of these statutes must be explained. Pertinent portions of the statutes are set out in the footnotes, and direct cites will be omitted in the text. 2

*1379 By the terms of Art. 46.02, a defendant may have the issue of present sanity tried in advance of the trial upon written request. Alternatively, during the trial on the merits, the court must hear evidence on the issue of present sanity on written request therefore, accompanied by a request for mistrial by reason of present insanity. The standard which must be used by the jury to determine present sanity is whether or ■ not the defendant is presently incapable of making a rational defense,

if the jury finds the defendant presently insane and there has been competent medical or psychiatric testimony to *1380 that effect, the jury then considers whether or not the defendant requires hospitalization in a mental hospital for his own welfare and protection or the protection of others. Where present insanity is found, no consideration on the merits can be made; further deliberations are confined to the need for commitment (as described above), and whether or not the defendant was sane or insane at the time of the alleged offense. It is apparent from the wording of the statute that a determination of present insanity must be followed by a determination of past sanity at the time of the alleged offense if any competent evidence is introduced by the defendant in reference to his past sanity. The choice as to whether or not to bring up the matter of past sanity as a defense is entirely that of the defendant, and the burden is on him to prove his insanity at the time of the offense by a preponderance of the evidence. Burton v. State, 471 S.W.2d 817 (Tex.Cr.App.1971). In deliberating past sanity, the usual standard for responsibility for criminal acts is followed — the ability to know right from wrong and the nature of one’s acts at the time of the offense. Wilkerson v. State, 423 S.W.2d 311 (Tex.Cr.App. 1968). If the defendant is found to have been insane at the time of the offense, he stands acquitted of the crime for which he was charged, and is in no sense a person charged with a crime.

Where a defendant is found insane at the time of trial and insane at the time of the offense (thereby becoming a member of the class of the “insane insane”) 3 and a determination is made that the former defendant (now an acquittee) is in need of hospitalization, he is confined to Rusk State Mental Hospital. 4 After confinement, the head of the hospital may at any time notify the committing court that the acquittee is now sane. No standard is set out as a prerequisite for release other than present sanity. A jury is impaneled if the judge finds that the request has merit in order to decide the patient’s present sanity, and if he is found sane, he is released. If found insane, he must be returned to Rusk for at least 180 days before another recommendation for release may be made. The acquittee, after a year of confinement, and each year thereafter, may initiate a judicial hearing for a sanity determination independent of the head of the hospital.

One portion of the statute which affords additional rights to those held to be incompetent to stand trial is Section 11. It provides that where a defendant is found to be insane and in need of hospitalization, where there is competent medical testimony that such person is a mentally retarded person, the court may commit him to a state school for the mentally retarded. The other provisions of the statute then apply.

By contrast, the Texas Mental Health Code, Article 5547, provides for the following actions in order to indefinitely commit a person civilly.

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678 F.2d 511 (Fifth Circuit, 1982)
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449 F. Supp. 1368 (W.D. New York, 1978)
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543 F.2d 178 (D.C. Circuit, 1977)
People v. Adams
343 N.E.2d 659 (Appellate Court of Illinois, 1976)
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344 A.2d 289 (Supreme Court of New Jersey, 1975)
Sheldon v. Reynolds
422 U.S. 1050 (Supreme Court, 1975)

Cite This Page — Counsel Stack

Bluebook (online)
381 F. Supp. 1374, 1974 U.S. Dist. LEXIS 6913, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reynolds-v-neill-txnd-1974.