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R.B. v. State

CRIMINAL LAW
Court of Appeals of Alaska (2023)
Olivia Wagner

In R.B. v. State, 533 P.3d 542 (Alaska Ct. App. 2023), the court of appeals held that (1) mandatory commitment of an incompetent felony defendant to the Alaska Psychiatric Institute (API) does not violate due process under either the United States or the Alaska Constitution, and (2) API is required to notify the court if it determines the defendant cannot be restored to competency within the maximum period of commitment. (Id. at 545). R.B. was charged with second-degree assault, fourth-degree assault, resisting arrest, reckless endangerment, second-degree criminal trespass, and disorderly conduct. (Id.). The superior court scheduled a competency hearing and found that R.B. was incompetent, thereby committing him to API for 90 days; the court did not, however, enter into a finding on whether R.B. was restorable to competency. (Id. at 547). On appeal, R.B. argued that the statute violated his substantive due process rights by mandating commitment of all incompetent felony defendants regardless of their likelihood for regaining competency. (Id.). The court of appeals affirmed the superior court’s decision that the statute does not violate due process, reasoning that the Alaska statute takes a flexible and case-oriented approach to determining the length of commitment by utilizing a cap on the maximum length of time a defendant may be committed and allowing for early release if restored to competency. (Id. at 552). However, API should notify the court not only when a defendant is restored to competency, but also when it becomes clear that further treatment is unlikely to be effective. (Id. at 555). The court of appeals articulated that this approach most accurately bears a reasonable relationship to the purpose of the commitment—to conduct further evaluation and provide restoration treatment. (Id.). Remanding the matter to the superior court on the second issue, the court of appeals held that (1) mandatory commitment of an incompetent felony defendant to the Alaska Psychiatric Institute (API) does not violate due process under either the United States or the Alaska Constitution, and (2) API is required to notify the court if it determines the defendant cannot be restored to competency within the maximum period of commitment. (Id. at 545).

R.B. v. State

CRIMINAL LAW
Court of Appeals of Alaska (2023)
Olivia Wagner

In R.B. v. State, 533 P.3d 542 (Alaska Ct. App. 2023), the court of appeals held that (1) mandatory commitment of an incompetent felony defendant to the Alaska Psychiatric Institute (API) does not violate due process under either the United States or the Alaska Constitution, and (2) API is required to notify the court if it determines the defendant cannot be restored to competency within the maximum period of commitment. (Id. at 545). R.B. was charged with second-degree assault, fourth-degree assault, resisting arrest, reckless endangerment, second-degree criminal trespass, and disorderly conduct. (Id.). The superior court scheduled a competency hearing and found that R.B. was incompetent, thereby committing him to API for 90 days; the court did not, however, enter into a finding on whether R.B. was restorable to competency. (Id. at 547). On appeal, R.B. argued that the statute violated his substantive due process rights by mandating commitment of all incompetent felony defendants regardless of their likelihood for regaining competency. (Id.). The court of appeals affirmed the superior court’s decision that the statute does not violate due process, reasoning that the Alaska statute takes a flexible and case-oriented approach to determining the length of commitment by utilizing a cap on the maximum length of time a defendant may be committed and allowing for early release if restored to competency. (Id. at 552). However, API should notify the court not only when a defendant is restored to competency, but also when it becomes clear that further treatment is unlikely to be effective. (Id. at 555). The court of appeals articulated that this approach most accurately bears a reasonable relationship to the purpose of the commitment—to conduct further evaluation and provide restoration treatment. (Id.). Remanding the matter to the superior court on the second issue, the court of appeals held that (1) mandatory commitment of an incompetent felony defendant to the Alaska Psychiatric Institute (API) does not violate due process under either the United States or the Alaska Constitution, and (2) API is required to notify the court if it determines the defendant cannot be restored to competency within the maximum period of commitment. (Id. at 545).