A Federal appeals court ruled that an insanity acquittee had to be committed, and two State appeals courts ruled that the Federal Constitution was violated when an acquittee's pretrial confinement was not credited against his commitment period and an acquittee was required to prove that he continued to be eligible for release. A Federal appeals court and the highest courts in two States ruled that a defendant could not seek habeas corpus review of the sufficiency of the evidence of his sanity, a trial court was required to weigh the evidence of insanity, and State due process was not violated where a defendant had the burden of proving his insanity. Two State supreme courts reversed convictions where a jury was not instructed on the consequences of not-guilty-by-reason-of-insanity and guilty-but-mentally-ill verdicts, and a defendant's postarrest silence was used to dispute his insanity claim. The Georgia Supreme Court set aside a guilty plea and death sentence, finding that the defendant was prejudiced by his attorney's failure to obtain an independent psychiatric evaluation that might have supported an insanity plea or provided crucial evidence in mitigation against the death sentence. The Georgia Court of Appeals ruled that a defendant who pled not guilty by reason of insanity had waived his right to challenge the testimony of a court-appointed psychiatrist.