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State of New Jersey v. Stefan Krol

344 A.2d 289 (1975)

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State of New Jersey v. Stefan Krol

New Jersey Supreme Court

344 A.2d 289 (1975)

Facts

Stefan Krol (defendant) was acquitted of stabbing his wife to death by reason of insanity, due to a schizophrenic delusion that caused Krol to believe his wife and employer were plotting his murder. The governing statute allowed for involuntary commitment without any consideration for an individual’s actual threat level, requiring only a finding by the jury that the insanity continues. Because the jury found that Krol remained insane, he was confined until such time that he evidenced a complete cure—the only means of establishing a restoration to reason. Krol challenged the constitutionality of the state’s involuntary-commitment procedure, arguing that the procedure violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The New Jersey Supreme Court granted certification, because this was an issue of first impression.

Rule of Law

Issue

Holding and Reasoning (Pashman, J.)

Dissent (Clifford, J.)

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