State v. Myron P., 19 N.Y.3d 205 (2012)

Under Mental Hygiene Law Article 10, there is no constitutional right to a jury trial on the issue of whether a detained sex offender requires inpatient confinement; a jury trial is required only on the initial determination of mental abnormality.

Summary

Myron P., convicted of attempted rape, challenged the denial of a jury trial on the determination of his confinement under Mental Hygiene Law article 10. He argued that he was entitled to a jury trial on whether his condition required inpatient confinement, similar to the rights afforded under article 9. The New York Court of Appeals held that article 10 respondents are not similarly situated to article 9 respondents due to differences in the nature of their mental disabilities, treatment needs, and public safety concerns. The Court affirmed that the legislature’s decision to assign the confinement determination under article 10 to a judge, rather than a jury, did not violate his constitutional rights.

Facts

Myron P. was convicted of attempted rape and sentenced to imprisonment followed by parole supervision. Prior to his release, he was transferred to the Sex Offender Treatment Program (SOTP) at Central New York Psychiatric Center (CNYPC) under Mental Hygiene Law article 9. CNYPC later applied for an order to retain him involuntarily under article 9. While the article 9 proceeding was pending, the Attorney General filed an article 10 petition seeking a determination that Myron P. was a detained sex offender requiring civil management and involuntary confinement.

Procedural History

Supreme Court denied Myron P.’s motion to stay the article 10 trial, holding that the article 9 claims were moot because the commitment basis had shifted to article 10. A jury found Myron P. to be a detained sex offender suffering from a mental abnormality. The Supreme Court, without a jury, then concluded he was a dangerous sex offender requiring confinement. The Appellate Division affirmed, holding sufficient evidence supported the jury verdict and that Myron P. was not deprived of his constitutional right to a jury trial on confinement. Myron P. appealed to the New York Court of Appeals.

Issue(s)

1. Whether the State violated Myron P.’s equal protection rights by not affording him the right to a jury trial on the issue of confinement, as provided to individuals subject to article 9.
2. Whether Mental Hygiene Law article 10 improperly deprived Myron P. of his state constitutional right to a trial by jury on the issue of whether he should be involuntarily committed to a secure facility.

Holding

1. No, because article 10 respondents are not similarly situated to article 9 respondents due to differences in their mental disabilities, treatment needs, and public safety concerns.
2. No, because the legislature’s decision to assign the determination of whether an individual’s dangerousness necessarily requires retention to a judge, rather than a jury, did not violate Myron P.’s state constitutional right to a jury trial.

Court’s Reasoning

The Court reasoned that the Equal Protection Clause requires similarly situated individuals to be treated alike, but article 10 respondents are a distinct category from article 9 respondents. The legislature enacted article 10 after determining that “sex offenders in need of civil commitment are a different population from traditional mental health patients, who have different treatment needs and particular vulnerabilities” (Mental Hygiene Law § 10.01 [g]). The confinement decision under article 9 (only confinement) differs significantly from article 10, which allows for either confinement or strict supervision and treatment (Mental Hygiene Law § 10.07 [f]).

Regarding the right to a jury trial, the Court noted that the New York Constitution guarantees trial by jury in cases where it was traditionally afforded before 1777, or extended by statute between 1777 and 1894, and also extends to new cases analogous to those traditionally tried by a jury. The Court acknowledged that historical civil commitment statutes provided a jury trial on mental illness and confinement need, but the judge was mandated to confine the individual upon a finding of mental illness. The legislature’s decision to assign the new determination of whether an individual’s dangerousness requires retention to a judge did not violate Myron P.’s state constitutional right. The court stated, “When the legislature assigned that new, purely remedial determination to a judge rather than a jury, it did not violate respondent’s state constitutional right to a jury trial.”