## Facts

- Michael Jones was charged in the District of Columbia with attempted petit larceny, a misdemeanor punishable by up to one year.
- After psychiatric evaluation, he was found not guilty by reason of insanity (NGRI) and automatically committed to a mental hospital under District of Columbia law.
- The statutory scheme provided a hearing within 50 days and periodic review; at release hearings, the insanity acquittee bore the burden to prove by a preponderance of the evidence that he was no longer mentally ill or dangerous.
- Jones remained hospitalized beyond one year and argued that continued confinement required use of civil-commitment procedures, which place the burden on the government and require clear and convincing proof of mental illness and dangerousness.
- The D.C. courts continued his commitment under the NGRI commitment framework.

## Issues

1. Whether an NGRI verdict is sufficient to justify commitment for treatment and public safety without requiring the government to prove mental illness and dangerousness under civil-commitment standards.
2. Whether due process permits indefinite confinement of an insanity acquittee when the acquittee must prove eligibility for release by a preponderance of the evidence.
3. Whether due process requires release, or a shift to civil-commitment procedures, once confinement exceeds the maximum sentence for the charged offense.

## Decision

- The Supreme Court affirmed.
- The Court held that an NGRI verdict is sufficiently probative of both mental illness and dangerousness to justify commitment for treatment and protection of the public.
- The Court held that indefinite commitment under the NGRI scheme, including use of a preponderance standard and placing the burden on the acquittee at release hearings, comports with due process.
- The Court rejected a rule tying the permissible duration of commitment to the maximum possible criminal sentence.
- Justices Brennan (joined by Marshall and Blackmun) and Stevens dissented, arguing for stronger procedural protections, particularly after confinement exceeds the maximum criminal sentence.

## Legal Principles

- An NGRI verdict supports an inference that the acquittee committed a criminal act because of mental illness, allowing commitment without a separate civil-commitment adjudication at the outset.
- Due process does not require the government to prove mental illness and dangerousness by clear and convincing evidence as a prerequisite to continuing confinement of an insanity acquittee under a specialized NGRI commitment framework.
- Due process permits allocating to the insanity acquittee the burden to prove, by a preponderance of the evidence, that he is no longer mentally ill or dangerous at release hearings, when the scheme provides periodic review.
- The maximum potential criminal sentence does not set a due process limit on the duration of confinement for an insanity acquittee; treatment needs and risk to the public may justify continued hospitalization.

## Conclusion

The Court upheld the District of Columbia’s scheme for committing and retaining insanity acquittees, ruling that an NGRI verdict justifies commitment and that due process allows continued confinement with periodic review and an acquittee-burdened preponderance standard, even when confinement may exceed the maximum sentence for the underlying charge.


Jones v. United States, 463 U.S. 354 (1983)