Man Declared Mentally Incompetent Solely Based on His Religious Beliefs

That’s what the Ohio Court of Appeals (State v. Daley, decided yesterday) said happened in the court below; the appellate court reversed the trial court’s mental incompetence finding.

Daley was charged in March 2010 with retaliation, intimidation, aggravated menacing, menacing, and telecommunications harassment. The charges stemmed from allegedly threatening voicemail messages left by Daley on the telephone messaging system of an employee of the Cuyahoga County Support Enforcement Agency (“CSEA”). The charges also stemmed from an allegedly threatening letter written by Daley to the CSEA employee.

The trial court referred Daley to the court’s psychiatric clinic for a competency evaluation and a hearing was held on same. The evaluating psychiatrist, Dr. Stephen Noffsinger, diagnosed Daley with psychotic disorder, not otherwise specified, and opined that Daley was not competent to stand trial because he was not able to assist in his defense. Daley declined an independent evaluation.

Daley testified at the competency hearing that he had been and was able to continue assisting his attorney in his defense. He also testified that his descriptions of the American legal system, such as his description of divorce court as the “high court of Satan,” were not meant to hurt anybody, but were based on his religious belief that divorce is against the word of God.

At the conclusion of the hearing, the trial court found Daley incompetent to stand trial and ordered him hospitalized for restoration to competency. The trial court also ordered that Daley be treated with antipsychotic medication if needed….

Upon review, we do not find that there was “some reliable, credible evidence supporting the trial court’s conclusion” that Daley was incompetent. Rather, Dr. Noffsinger’s opinion that Daley was incompetent, formulated after an hour and ten-minute evaluation, was based solely on Daley’s religious beliefs. Specifically, Dr. Noffsinger opined that Daley, a “radical Christian,” “expresses such extreme intensity of religious belief in very unorthodox religious beliefs to the point to constitute psychosis.” Noffsinger further testified that treating Daley would “change his psychotic symptoms of which are a religious theme[,]” so that his “intensity and [ ] preoccupation with his religious beliefs will be greatly decreased.”

Daley’s religious beliefs are constitutionally protected, however. Because the record demonstrates that Dr. Noffsinger’s diagnosis was based solely on Daley’s religious beliefs, we find that the trial court erred in finding him incompetent.

UPDATE: Note these related posts, Is a Patient Who Believes “Jesus Would Save [Me]” Competent to Refuse Life-Saving Medical Treatment? (July 2010) and May Court Order Hysterectomy as Treatment for Cancer, on the Grounds that the Woman’s Refusal Is Based on a Religious Delusion? (March 2011).