State of Tennessee v. Johntavius Griggs

In this interlocutory appeal pursuant to Tennessee Rule of Appellate Procedure 9, we review the trial court’s order denying the motion of Defendant, Johntavius Griggs, for release from custody after he was found to be incompetent to stand trial for first degree murder due to his intellectual disability. The trial court found that the conclusion of psychiatrists designated by the Department of Intellectual and Developmental Disabilities (“DIDD”)1 that Defendant was ineligible for involuntary commitment was based on their misinterpretation of the statutory provisions governing the involuntary commitment of defendants found to be incompetent to stand trial due to intellectual disability. The trial court ordered additional evaluations by DIDD-designated physicians or psychologists to determine Defendant’s eligibility for involuntary commitment. Upon review, we conclude that the DIDD-designated psychiatrists misinterpreted the applicable statutory provisions in determining that Defendant did not meet the statutory requirements for involuntary commitment. Accordingly, we affirm the trial court’s judgment denying Defendant’s motion for release from custody, and we remand for further proceedings consistent with this opinion.