## Facts

- Peter R. Mayock was confined at a Connecticut state mental hospital and sought release by habeas corpus, claiming his current condition did not require involuntary confinement.
- Mayock was first hospitalized in 1943, released in 1944, and recommitted in 1944 after removing his right eye.
- He was unconditionally discharged in July 1947; three days later he removed his right hand and was recommitted, remaining hospitalized thereafter.
- While hospitalized, Mayock performed responsible duties, including operating a newsstand handling money and managing a recreation center for parole-privileged patients.
- Mayock sincerely believed he was a prophet with a divine message and that God may call for a “peace offering” through sacrificing a body part; he admitted he would cut off a foot if commanded by God, though he had no present plan to do so.
- A staff psychiatrist diagnosed Mayock with paranoid schizophrenia and testified that his “grossly false” religious beliefs and past self-mutilations were manifestations of mental illness; the psychiatrist assessed a continuing risk of further self-mutilation if released.

## Issues

1. Whether Mayock’s continued involuntary confinement was unlawful because his present mental condition did not require custodial care.
2. Whether continued confinement, given the religious form of Mayock’s beliefs and conduct, violated the constitutional right to free exercise of religion.

## Decision

- The Connecticut Supreme Court affirmed the dismissal of the habeas petition.
- The evidence supported the trial court’s finding that Mayock’s present mental condition required continued custodial care for his welfare, including protection against further self-mutilation.
- The court rejected the claim that confinement was imposed because of religion, holding that the free exercise right was not unconstitutionally infringed.
- The court applied a deferential appellate standard, sustaining the trial court’s conclusions unless legally or logically inconsistent with the facts found or based on an erroneous legal rule.

## Legal Principles

- In habeas challenges to civil commitment, an appellate court will uphold the trial court’s conclusions if they are consistent with the factual findings and rest on correct legal standards.
- Continued involuntary confinement is lawful when supported by evidence that, because of mental illness, the individual requires custodial care to protect health and welfare, including from serious self-harm.
- The free exercise clause is not violated when the state confines an individual for reasons of mental illness and protective care, even if the individual’s dangerous conduct is religiously framed, so long as the confinement is not aimed at suppressing religious belief.

## Conclusion

The court upheld Mayock’s continued civil commitment because the record supported a finding of ongoing mental illness with a serious risk of future self-mutilation, and the confinement was a protective response to that condition rather than an unconstitutional restriction on religious exercise.


Mayock v. Martin, 157 Conn. 56, 245 A.2d 574 (1968)