Dodd v. Hughes

Dodd (plaintiff) applied for a writ of habeas corpus to be released from a state hospital where he was confined following a long history of mental illness and violent criminal behavior. Dodd was clinically diagnosed as sociopathic but did not exhibit any psychotic reactions indicated by the American Psychiatric Association to be classified as psychotic. However, Dodd’s history of mental illness and incarceration was documented from as early as age eight, when Dodd was confined to a boys’ school for two years following run-ins with police. Dodd escaped from the school and while on the run assaulted an elderly man with a crowbar and set the man on fire. Dodd was then sent to a prison for hardcore youth criminals and from there was committed to the hospital from which he sought release. At Dodd’s habeas hearing, the hospital’s superintendent testified that Dodd was not clinically psychotic and therefore not “mentally ill” as the term was used by the state to authorize confinement. Another doctor testified that although Dodd was not psychotic, he could still be deemed mentally ill. Following the hearing, a district-court judge determined that Dodd was mentally ill within the meaning of the state-hospital law and ordered that Dodd be confined to a state prison through the state’s procedure for such confinement. The judge’s order was effectuated, and Dodd was confined to a state prison. Dodd appealed.