RALPH ARNOLD SMITH, JR.
MISSISSIPPI DEPARTMENT OF MENTAL HEALTH AND JAMES G. CHASTAIN, DIRECTOR OF THE MISSISSIPPI STATE HOSPITAL
OF JUDGMENT: 07/11/2016
COUNTY CHANCERY COURT, HON. DENISE OWENS.
COURT ATTORNEYS: WILLIAM CHARLES BELL BENNY McCALIP
“MAC” MAY HAROLD EDWARD PIZZETTA, III JOHN H.
ATTORNEY FOR APPELLANT: WILLIAM CHARLES BELL.
ATTORNEYS FOR APPELLEES: OFFICE OF THE ATTORNEY GENERAL BY:
BENNY McCALIP “MAC” MAY HAROLD EDWARD PIZZETTA,
RANDOLPH, P.J., MAXWELL AND BEAM, JJ.
Dr. Ralph A. Smith Jr. was arrested and indicted in a
murder-for-hire plot in 2012. He was eventually committed to
the Mississippi State Hospital at Whitfield, where he has
been treated for mental illness. Soon after his arrival at
Whitfield, the facility's director recommended Dr.
Smith's illness required continual, involuntary treatment
and that he should remain committed at the facility. Dr.
Smith disagreed with the recommendation and has contested his
commitment to Whitfield at every step. Most recently, Dr.
Smith filed in Hinds County Chancery Court a habeas petition
and motion for relief from the chancellor's ruling that
ordered his continued inpatient treatment. Dr. Smith argues
he has been improperly confined to Whitfield and should be
released immediately or discharged to an outpatient facility.
The chancellor denied his petition and motion for relief. And
on appeal, Smith argues his habeas petition was wrongly
denied and the Mississippi Department of Mental Health lacked
standing to oppose his requests. But during the pendency of
this appeal, Dr. Smith was discharged from Whitfield to an
outpatient facility. So the relief he requests in this appeal
can no longer be granted by this Court. We thus dismiss his
appeal as moot.
Facts and Procedural History
In 2012, Dr. Smith was arrested and indicted for capital
murder, conspiracy, and burglary. In October 2014, a Leflore
County Circuit Court judge declared Dr. Smith incompetent to
stand trial. Based on this ruling, the Leflore County
District Attorney's Office filed an affidavit in chancery
court to begin civil-commitment proceedings. After
examinations by a court-appointed physician and psychologist
and two hearings, on January 16, 2015, Special Chancellor
Hollis McGehee ordered Dr. Smith to be committed to the
Mississippi State Hospital at Whitfield.
Soon after his arrival at Whitfield, Dr. Smith requested a
hearing in Hinds County Chancery Court. The purpose of the
hearing was to determine if continued commitment was
necessary. Chancellor Denise Owens appointed counsel
for Dr. Smith. She also assigned the hearing to a special
master. The hearing took place at Whitfield on March 10,
2015. The special master heard testimony from a physician and
psychologist, both employed at Whitfield, that Dr. Smith
needed continued "forced treatment" for "a
persistent mental disorder." The special master agreed
that Dr. Smith's continued treatment at Whitfield was
necessary and was the least restrictive alternative. Based on
the special master's findings, Judge Owens entered an
order on March 10, 2015, continuing Dr. Smith's
commitment at Whitfield.
On October 13, 2015, Dr. Smith filed a motion requesting a
hearing before Judge Owens. He argued that Whitfield's
director had not completed the six-month examination required
under Mississippi Code Section 41-21-99. And he insisted
he should be released from Whitfield or discharged to an
outpatient facility. The Mississippi Department of Mental
Health (the Department), through the Attorney General's
Office, responded that Dr. Smith had received his six-month
examination on May 8, 2015. They asserted the examination was
part of his clinical record. And the next examination was
scheduled for November 7, 2015.
Judge Owens held hearings on December 4 and 18, 2015, and
heard extensive testimony about Dr. Smith's mental
condition. Dr. Smith called his wife, a counselor from Hinds
Behavioral Health Services, and a forensic psychologist from
Whitfield as witnesses. The gist of their testimony was that
outpatient treatment was sufficient both to treat Dr. Smith
and to protect the community. The Department disagreed.