AAPL Landmark - Death Penalty Flashcards
(13 cards)
Is the information gathered as part of the pretrial psychiatric evaluation admissible during the sentencing phase of a death penalty case when used for that purpose without the knowledge or consent of the defendant at the time of the evaluation?
No.
Estelle v. Smith (1983), USSC.
Smith murdered a store clerk and was sentenced to death; he requested a habeas corpus proceeding.
Smith’s attorney was unaware that the court had ordered a competency evaluation. Dr. James Grigson used information from the competency evaluation to testify in the penalty phase about future dangerousness.
The USSC agreed with the 5th Circuit that this violated Mr. Smith’s protection from self-incrimination (5th Amendment) and his right to counsel (6th Amendment) had been violated.
Does the state have to provide access to psychiatric evaluation for an indigent defendant in a case where legal sanity is at issue?
Yes.
Ake v. Oklahoma (1985). USSC
Ake and his colleague, Hatch, posed as lost motorists and broke into the Douglass home. They murdered the parents and wounded two children. Ake claimed he was insane at the time of the crime, but was not allowed access to a psychiatrist to assess criminal responsibility due to his indigent status.
The USSC found that the state violated the 14th Amendment’s guarantee of due process by denying the defendant a psychiatric consultant “who will conduct an appropriate examination and assist in evaluation, preparation, and presentation of the defense.”
Can an insane prisoner be executed?
No.
Ford v. Wainwright (1986). USSC
Ford was convicted of murder and sentenced to death, with a mix of opinions from psychiatrists about his competence to be executed. The Florida governor had the final say based on the psychiatric reports.
The USSC found the Florida statute governing this competency determination unconstitutional because it allowed the finding to be carried out by the executive branch. The Court opined that a “full and fair hearing” was required, noting that this level of due process was required because executing the insane is inherently offensive and does not meet the goals of either retribution or deterrence. The 8th Amendment forbids the execution only of those unaware of the punishment they are about to suffer and why they’re to suffer it.
Is the inclusion of victim impact statements during the sentencing phase of a capital trial a violation of the Eighth Amendment?
No.
Payne v. Tennessee (1991). USSC
Payne killed a mother and her child and injured her other child. The grandmother testified at sentencing. The USSC went against precedent, saying that the victim impact statements show the specific harm caused by the crime, which aids the jury in assessing the defendant’s moral culpability and shows the victim as a unique individual.
The USSC overruled its prior decisions, Booth and Gathers, stating that victim impact statements were allowed.
Can a state involuntarily treat a death row prisoner with antipsychotic drugs to make him competent to be executed?
No.
State v. Perry (1992). Louisiana Supreme Court
Perry murdered his family and was sentenced to death. He had schizoaffective disorder and was competent for execution only with the use of Haldol.
In a per curiam decision, the Court vacated the lower court’s ruling without issuing an opinion. Given Washington v. Harper (1990), also a case involving involuntary medication, which had been decided after the District Court’s ruling, the case was remanded to the Louisiana Supreme Court for further deliberation.
Upon remand, the lower court ruled against the forcible medication of individuals to maintain their competency for execution. This decision was based on the distinction that, unlike the holding in Harper v. Washington concerning involuntary medication for treatment issues, forcing medication for execution was not medical treatment (being “antithetical to the basic principles of the healing arts”) but punishment.
Does the Constitution prohibit the execution of a person with mental retardation?
Yes.
Atkins v. Virginia (2002). USSC
Daryl Atkins was convicted of abduction, armed robbery, and capital murder and sentenced to death. FSIQ was 59 by a defense psychologist, which the State expert contested.
The USSC overturned its previous decision in Penry v. Lynaugh and ruled that executing an individual with ID was inconsistent with evolving standards of decency that define what is considered cruel and unusual punishment under the 8th Amendment.
Does the Constitution prohibit the execution of an individual who committed a capital crime when he was under the age of 18?
Yes.
Roper v. Simmons (2005). USSC
17 y/o pushed a woman off a bridge in Missouri. In light of Atkins v. Virginia, the same rationale should apply to juveniles.
The USSC agreed with the MO SC, contrary to the USSC’s previous ruling in Stanford v. Kentucky, by stating that a death sentence for a crime committed before 18 years of age was a violation of the 8th and 14th Amendments.
The scientific community viewed adolescence as a period of poor decision-making, developmental immaturity, and susceptibility to peer pressure, all of which rendered adolescents less culpable than adults and, therefore, not deserving of the ultimate penalty of death.
An “evolving standard of decency” was cited in the decision.
Are a “rational understanding” and a “factual awareness” necessary for a person to be found competent to be executed?
Yes.
Panetti v. Quarterman (2007). USSC.
Panetti shot and killed his wife’s parents in front of his wife and daughter. He believed the state was executing him to stop him from spreading the gospel, but he demonstrated a factual account of his situation.
The USSC reversed the 5th Circuit, stating that Ford required consideration of both factual awareness and a “rational understanding” of the reasons for being executed.
Does a death row inmate have the right to suspend federal habeas corpus proceedings when found incompetent to assist counsel?
No.
Ryan v. Gonzales (2013). (not landmark) The USSC reasoned that there was no constitutional right to competence for federal habeas corpus proceedings.
Does the 8th Amendment prohibit the use of outdated medical standards for determining intellectual disability in death penalty cases?
Yes. Moore v. Texas (2017). (not landmark)
When deciding if an inmate on death row is qualified as “intellectually disabled,” as under Atkins v. Virginia (2002), courts may not ignore dominant medical guidelines. Texas tried to say it’s ID standard was a “consensus of Texas citizens.”
Is it a violation of the Constitution to rely on a strict IQ score in determining intellectual disability for the purposes of death penalty proceedings?
Yes.
Hall v. Florida (2014). USSC.
Freddie Hall was an accomplice to kidnapping, beating, raping, and murdering Karol Hurst. He had an FSIQ of 71, and Florida law required an IQ of 70 or below.
United States Supreme Court case in which the Court held that a bright-line IQ threshold requirement for determining whether someone has an intellectual disability (formerly mental retardation) is unconstitutional in deciding whether they are eligible for the death penalty. FL did not consider various relevant factors in deciding whether someone is ID.
Does Ake v. Oklahoma guarantee an indigent defendant access to expert psychiatric consultation at trial, and if it is relevant to sentencing?
Yes. (not landmark)
McWilliams v. Dunn (2017). An indigent defendant facing the death penalty must have access to a competent psychiatrist who will conduct an appropriate examination and assist in evaluating, preparing, and presenting the defense, or habeas relief may be appropriate.
Can hypothetical questions be used to determine dangerousness in the sentencing phase?
No.
Barefoot v. Estelle, 1983, USSC.
Thomas Barefoot was convicted of capital murder of a police officer. Dr. James Grigson testified about Mr. Barefoot’s dangerousness based on hypothetical scenarios. He was sentenced to death and appealed by habeas corpus to the Federal Court.
The USSC rejected Barefoot’s claim and said, “Psychiatrists are wrong with respect to future dangerousness, only most of the time.”
