Payne v. Fairfield Hills Hospital

The sole issue in this appeal is the constitutionality of the 1985 statute creating the psychiatric security review board (PSRB), an agency charged with monitoring the mental condition of persons acquitted of criminal charges by reason of mental disease or defect, with respect to a pre-1985 acquittee. The plaintiff, James Payne, acquitted of murder by reason of mental disease or defect and confined to a mental hospital in 1980, sought to enjoin the PSRB from exercising jurisdiction over him on the ground that the statute creating the board is a “quasi-criminal” statute that violates the ex…