Commonwealth v. A.Z.Annotate this Case
The case concerns the constitutional rights of a criminal defendant, A.Z., who was involuntarily hospitalized for a competency determination under Massachusetts law, G. L. c. 123, § 15 (b). The Supreme Judicial Court of Massachusetts held that the involuntary commitment of a criminal defendant for a competency determination infringes upon a defendant's fundamental right to liberty and thus must satisfy strict scrutiny under the Massachusetts Declaration of Rights and the United States Constitution. To pass strict scrutiny, the involuntary commitment must be the least restrictive means available to vindicate the governmental interest at stake. Therefore, it is unconstitutional for a court to hospitalize a pretrial defendant for a clinical evaluation and observation of competency, absent a finding by the judge, by clear and convincing evidence, that hospitalization is the least restrictive means available to adequately determine a criminal defendant's competency to stand trial. The judge in this case did not make such findings, so the court concluded that the defendant's constitutional rights were violated.