Jackson (defendant) was a deaf mute with the mental capacity of a pre-school aged child. Jackson was charged with criminal offenses relating to two petty robberies. The trial court conducted a competency hearing. The examining doctors concluded that Jackson was unable to understand the nature of the proceedings against him or to participate in his own defense. The doctors opined that it was highly unlikely Jackson would ever develop the communication skills necessary to render him competent to stand trial. The trial court ordered Jackson committed to a mental institution until such time as he was found sane. Jackson moved for a new trial on grounds that there was no evidence that he was insane and no evidence that he would ever become competent to stand trial. Jackson argued that the commitment amounted to a life sentence in the absence of a criminal conviction which violated his Fourteenth Amendment rights to due process and equal protection.