Lynch v. Overholser, 369 U.S. 705 (1962)

Lynch v. Overholser


No. 159


Argued January 15, 1962
Decided May 21, 1962
369 U.S. 705

CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

Syllabus

After petitioner had received treatment in a mental hospital, a psychiatrist advised the court that he was able to stand trial, but that he was suffering from a mental disease, and that further treatment would be advisable. Petitioner was then brought to trial in the District of Columbia on two charges of passing worthless checks. On advice of counsel, he sought to withdraw an earlier plea of not guilty and to plead guilty to both charges, but the judge refused to permit him to do so. Although petitioner maintained that he was mentally responsible when the offenses were committed, and presented no evidence to support an acquittal by reason of insanity, the trial judge concluded that he was not guilty on the ground that he was insane at the time of the commission of the offense, and ordered him committed to a mental hospital under D.C. Code § 24-301(d), which provides that,

If any person . . . is acquitted solely on the ground that he was insane at the time of [the] commission [of the offense], the court shall order such person to be confined in a hospital for the mentally ill.

In this habeas corpus proceeding, held: the trial court erred in ordering petitioner committed, because § 24-301(d) applies only to a defendant who, by his own act, has relied on a defense that he was insane when the offense was committed, and who is acquitted on that ground. Pp. 706-720.

109 U.S.App.D.C. 404, 288 F. 2d 388, reversed.