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Decision by Biden Judge Limits Involuntary Confinement of Mentally Ill

Lady Justice
News & Analysis

Judge Toby Heytens, nominated by President Biden to the Fourth Circuit, wrote an important 2-1 decision that limited the government’s ability to confine indefinitely a mentally ill person being released from prison. Trump judge Julius Richardson dissented in the November 2022 ruling in US v Williams.

 Nathaniel Williams suffers from bipolar schizoaffective disorder which, if not properly treated, causes hallucinations and disruptive or violent behavior. He was convicted and sentenced to prison for four years for assaulting a security guard. After serving his sentence, the sentencing court required that Williams comply with a number of conditions of supervised release, including taking all prescribed medications and participating in a mental health treatment program.

After some struggle, Williams began to take the prescribed medication.  As a result, he became “psychiatrically stabilized” and “engaged in no violent behavior.” Because of concern that he might not take the medication when released, however, a different judge ordered that instead of release,  Williams must be civilly committed and detained for an indefinite period. The court did not specifically consider his supervised release conditions.

Judge Heytens reversed the lower court. He ruled that before requiring indefinite confinement of a mentally ill person being released from prison, the court “must consider” specifically the “term of supervision that would govern” the person upon release. Based on past precedent, he explained, the lower court was “required to at least consider” whether those terms were “ultimately enough to ensure Williams’ safe release.”

Judge Heytens’ decision will help ensure more humane treatment and prevent unwarranted civil commitment of mentally ill people. It provides another illustration of the importance of promptly confirming fair-minded judicial nominees by President Biden.