Byrd was arrested on charges of murder and armed robbery, but the trial court found she was incompetent to stand trial due to mental retardation. She was then committed to a state institution. After two years, her attorney moved to dismiss the criminal charges under a state statute authorizing this in cases of mental retardation, and asked that she be civilly committed. The State argued that the Florida Supreme Court had adopted a rule of procedure extending the period to five years and that this rule superseded the statute. The trial court agreed, as did the First District Court of Appeal.