Rhode Island Supreme Court rules a defendant on outpatient competency commitment must be discharged within 30 days of being found nonrestorable
In a July 2, 2024 opinion, the Rhode Island Supreme Court reviewed Superior Court orders that denied a defendant's petitions to be discharged from commitment orders under the state's competency statute. The man was ruled incompetent in June 2018 and was placed in an unlocked group home in 2019, with a return to Eleanor Slater Hospital if he broke its rules. In 2020 the hospital's forensic psychiatrist concluded his competency was nonrestorable before the charges would be dismissed, but the Superior Court reasoned that the group home was not "detention" under the statute.
The justices disagreed. Reading the remedial statute broadly, they held that outpatient placement under a commitment order is detention, and that, with the nonrestorability finding undisputed, due process principles from Jackson v. Indiana and the court's earlier State v. Morin decision require discharge 30 days after the finding. The court noted the state may still seek civil commitment of a potentially dangerous defendant, and it declined to order the charges dismissed.
The decision settles that the statute's thirty-day discharge rule applies to community placements as well as hospital commitments.
Source: State v. Edward Mather — Rhode Island Supreme Court, by Rhode Island Supreme Court (Justice Long, for the Court)
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