In the Lynch v. Overholser case of 1961, the U.S Supreme Court examined whether a defendant could be involuntarily committed to a mental institution without being given an opportunity for judicial review. The petitioner, Lynch, had been charged with forgery and pleaded insanity as his defense. He was then committed to St Elizabeth's Hospital in Washington D.C., under federal law which allowed such commitment if it was determined that he would likely endanger himself or others if released. However, no hearing took place before this decision was made. Lynch appealed his commitment arguing that it violated his constitutional rights because he wasn't provided with due process of law - specifically, he wasn't granted a hearing prior to being institutionalized. The Supreme Court ruled in favor of Lynch stating that although Congress has broad power over those who are mentally ill and have been involved in criminal proceedings; they must still provide them with basic procedural protections including notice and an opportunity for hearing before committing them indefinitely into mental institutions.

In the dissenting opinion for Lynch v. Overholser, Justice Frankfurter disagreed with the majority's decision to allow a defendant who had been found not guilty by reason of insanity to be committed involuntarily without a jury trial. He argued that this violated the defendant's constitutional rights under the Fifth and Sixth Amendments, which guarantee due process and trial by jury in criminal cases. Furthermore, he contended that it was inconsistent with previous court rulings on similar issues. According to him, if an individual is acquitted based on mental illness but still poses a danger to society or themselves, they should be civilly committed through proper legal procedures rather than being indefinitely detained without their consent or any judicial review of their condition.