Washington v. Beaver (Majority)
Annotate this CaseIn 2005, Rickey Beaver was found not guilty by reason of insanity on a charge of residential burglary. The court found that Beaver suffered from a mental disease or defect and held that he posed a substantial danger to other persons and presented a substantial likelihood of committing criminal acts jeopardizing public safety or security unless kept under further control by the court. The court committed Beaver to Western State Hospital (WSH) and to the custody of the secretary of the Department of Social and Health Services. Beaver was granted a conditional release in 2007. Between 2007 and his final discharge in 2014, Beaver violated the terms of his conditional release several times. In 2011, Beaver petitioned for final discharge. WSH recommended Beaver's final discharge, but the Public Safety Review Panel (PSRP) opposed it. A jury trial was held, but before resting, Beaver voluntarily withdrew his petition. Beaver agreed that he continued to suffer from a mental illness that made him a threat to public safety, and stipulated to an agreed order of conditional release. On conditional release, Beaver violated the terms by using cocaine, drinking alcohol, and driving a motor vehicle, and by being charged with the crime of driving under the influence of alcohol. In 2013, the State successfully moved to revoke Beaver's conditional release. Beaver appealed the trial court's order revoking his conditional release, arguing that due process required a finding of current mental illness before the court could revoke his conditional release and recommit him to WSH. While this appeal was pending, Beaver filed a petition for final discharge under RCW 10.77.200(3). Based on agreement of the parties, Beaver was granted conditional release in October 2013. Then in May 2014, again based on agreement of the parties, Beaver was granted final discharge. Although the Court of Appeals found that the case was moot, it reviewed the merits and held that substantive and procedural due process did not require a judicial finding of current mental illness before the court could revoke conditional release. The issue this case presented for the Supreme Court's review centered on the appellate court's holding. Chapter 10.27 RCW, the statutory scheme that governed insanity acquittals, required the trial court find that a conditionally released insanity acquittee violated the conditions of release or posed a threat to the public to revoke an insanity acquittee' s conditional release. The Court found that the statute did not require the trial court make a finding regarding the acquittee's mental state at a conditional release revocation hearing. The Court therefore held that the statute satisfied due process and affirmed the Court of Appeals.
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