Matter of Jamie R., 6 N.Y.3d 138 (2005)
An insanity acquittee classified as suffering from a dangerous mental disorder and confined to a secure facility cannot challenge that placement decision for a second time via a rehearing and review proceeding; the only issue for rehearing is whether any confinement is warranted.
Summary
Jamie R., an insanity acquittee, sought a second review challenging his secure facility placement. He argued that a jury in a rehearing and review proceeding could revisit the dangerous mental disorder determination. The Court of Appeals held that rehearing and review is limited to the fundamental question of whether any confinement by the Office of Mental Health (OMH) is warranted, not the specific placement within OMH facilities. The Court emphasized that challenges to secure placement should be pursued through a direct appeal of the initial placement order, and this interpretation balances public safety with individual rights.
Facts
Jamie R. was charged with assault in 1998. He was initially found incompetent to stand trial due to paranoid schizophrenia. He later pleaded not responsible by reason of mental disease or defect, becoming subject to CPL 330.20. In 1999, he was classified as a track two patient (mentally ill, but not dangerous) and placed in a nonsecure facility. He was discharged twice but readmitted due to disruptive and threatening behavior. He was arrested multiple times for off-premises incidents, including assault and harassment. Due to these escalating issues, OMH sought to reclassify him as a track one patient (suffering from a dangerous mental disorder) and place him in a secure facility.
Procedural History
In 2003, Dutchess County Supreme Court granted OMH’s application to reclassify Jamie R. as a track one patient and ordered placement in a secure facility. Jamie R. did not appeal this order. Instead, he filed a petition for jury rehearing and review in New York County Supreme Court. The jury found that Jamie R. was mentally ill but did not currently pose a physical danger. The Supreme Court initially ordered a transfer to a nonsecure facility but then resettled the order, denying the recommitment application altogether. The Appellate Division reversed, reinstating the Dutchess County Supreme Court’s recommitment order. Jamie R. appealed to the Court of Appeals.
Issue(s)
Whether an insanity acquittee, found to suffer from a dangerous mental disorder and consequently placed in a secure facility, can challenge that placement decision a second time through a rehearing and review proceeding under CPL 330.20 and Mental Hygiene Law § 9.35.
Holding
No, because the scope of a rehearing and review proceeding is limited to determining whether any confinement by the OMH is warranted, not the specific type of facility. This determination of dangerousness and facility placement should be challenged via direct appeal.
Court’s Reasoning
The Court of Appeals relied on its prior decision in Matter of Norman D., which held that an insanity acquittee could not challenge their track one classification in a rehearing and review proceeding. The Court reasoned that CPL 330.20 (16) incorporates Mental Hygiene Law § 9.35, which limits the scope of rehearing and review to the “question of the mental illness and the need for retention of the patient.” This language does not encompass the “dangerous mental disorder” determination that justifies track one classification and secure facility placement. The Court highlighted that track status is unique to insanity acquittees and inapplicable to civil patients, meaning the legislature did not intend for it to be reviewed during civil-style rehearing. The Court noted that the legislative intent of CPL 330.20 was to balance public safety and individual rights; allowing a second challenge to facility placement would undermine this balance. Further, this ruling maintains procedural parity between insanity acquittees and civilly committed patients, who do not have a right to rehearing and review for administrative transfer decisions. The Court emphasized that the dangerous mental disorder determination is still subject to judicial review through a direct appeal under CPL 330.20 (21) and periodic retention hearings.