## Facts

- Monte Dean Dodd was committed to the Nevada State Hospital as a “mentally ill” person by district court order.
- Dodd sought release by petitioning for habeas corpus under Nevada’s mental health statutes.
- At the habeas hearing, medical testimony agreed Dodd had a sociopathic personality and was not psychotic under American Psychiatric Association classifications.
- The hospital superintendent testified Dodd was not psychotic and therefore not “mentally ill” under the statute, recommending release.
- Another physician testified a sociopathic personality could qualify as “mentally ill” under the statute and stated Dodd had a high potential for homicidal activity.
- The district court found Dodd mentally ill, a menace to public safety, and that hospital facilities were inadequate for safe confinement; it ordered proceedings to confine him in the Nevada State Prison under NRS 433.310, and Dodd was transferred there.
- On appeal, the record did not show a separate “minute order” denying habeas relief; the Supreme Court treated the prison commitment order as the denial of habeas relief and exercised jurisdiction.

## Issues

1. Whether “mentally ill” under Nevada’s hospital-commitment statutes is limited to persons with technically classified psychotic reactions.
2. Whether a dangerous sociopathic personality may be deemed “mentally ill” for purposes of involuntary confinement under NRS 433.
3. Whether the evidence supported the findings that Dodd was mentally ill, dangerous, and could not be safely confined in the state hospital, justifying prison confinement under NRS 433.310.
4. Whether the Supreme Court could treat the commitment order as a denial of habeas relief for appellate jurisdiction.

## Decision

- The Nevada Supreme Court affirmed the district court’s order and upheld the denial of habeas relief.
- The Court held that “mentally ill” in NRS 433 is not confined to American Psychiatric Association psychotic classifications.
- The Court upheld the finding that Dodd’s sociopathic personality could constitute mental illness under the statute, given the evidence of dangerousness.
- The Court found sufficient evidence that Dodd was a menace to public safety and that hospital facilities were inadequate for his safe confinement, supporting prison confinement under NRS 433.310.
- The Court treated the prison commitment order as the functional denial of habeas relief and assumed jurisdiction under NRS 34.380(3).

## Legal Principles

- When a mental health statute does not define “mentally ill,” courts may construe the term as a legal standard tied to legislative purpose and public safety, not solely to technical psychiatric categories.
- “Mentally ill” for involuntary confinement need not be limited to formally classified psychoses; a sociopathic personality may qualify within the statutory meaning.
- Appellate review will sustain a commitment order when the record supports findings of mental illness (as legally defined), dangerousness, and inadequacy of less restrictive or less secure facilities under the governing statute.
- A commitment order that effectuates continued confinement may be treated as the denial of habeas corpus relief for purposes of appellate jurisdiction where the proceedings and record show that habeas relief was sought and rejected.

## Conclusion

The court upheld continued confinement by ruling that Nevada’s statutory term “mentally ill” is not restricted to technical psychosis classifications and may include a dangerous sociopathic personality, and it affirmed the order authorizing prison confinement after findings of dangerousness and inadequate hospital security.


Dodd v. Hughes, 81 Nev. 43, 398 P.2d 540 (Nev. 1965)