Case Law Flashcards
Dusky v. United States (1960)
Facts:
- Milton Dusky was charged with kidnapping and sexually assaulting a teenage girl
- Lawyer sent him for a competency evaluation where he was given a brief mental status examination
- He was diagnosed with schizophrenia and opined competent
Issue: Is a brief mental status examination sufficient to establish a defendant’s competency to stand trial? Should more stringent criteria be used?
Holding: A brief mental status examination is insufficient to establish competency to stand trial. “Test must be whether he has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding - and whether he has a rational as well as factual understanding of the proceedings against him.”
Drope v. Missouri (1975)
Facts:
- James Drope was charged with the forcible rape of his wife
- Defense requested continuance so a psychiatrist could examine him and provide treatment but no action was taken on the motion
- Drope was absent from second day of trial because he attempted suicide
- Defense called for a mistrial, but the judge denied it saying Drope’s absence was voluntary
- The trial continued and he was convicted and sentenced to life
Issue: Did the lower court’s violate Drope’s due process rights by proceeding with his trial when he was not present, and should his trial have been suspended until a competency determination was made? Was there sufficient evidence to question his competence?
Holding:
- ) The trial court failed to give proper weight to evidence of the petitioner’s incompetence.
- ) The correct course was to suspend trial until a competency determination could be made.
- ) There was insufficient inquiry to determine whether the petitioner’s right to be present should be waived.
- ) Remanding the case for psychiatric evaluation did not adequately protect due process rights; however, the state could retry the case IF the defendant was competent to be tried.
Important considerations: Supreme Court acknowledged that competence is not fixed, and just because a defendant is competent at the beginning of a trial doesn’t mean that their ability to meet the competency standards won’t change over the course of the proceedings.
Pate v. Robinson (1966)
Facts:
- Robinson was convicted of murdering his wife and sentenced to life
- Defense had raised competency at trial and appealed the conviction because nothing had been done about it
Issue: Whether the appellant was entitled to a hearing on his competency to stand trial and whether or not being granted such a hearing was a violation of the due process clause of the Constitution (14th Amendment)
Holding: A hearing must be held if there is a “bona fide doubt” about the defendant’s competence as the conviction of a legally incompetent persons violates due process. Furthermore, if the defendant does not request a competency hearing, the judge should order one if sufficient evidence exists to warrant such a hearing.
Wilson v. United States (1968)
Facts:
- Robert Wilson was tried and convicted of five counts of assault with a pistol and robbery.
- During the offense he was involved in a car accident and suffered an injury that resulted in permanent retrograde amnesia.
- He was hospitalized for a mental examination, and the evaluator opined that he was of sound mental health but incompetent to stand trial because of his amnesia.
- He was hospitalized for 14 months and then returned to court where an expert testified that Wilson had a rational understanding of the charges against him.
- Judge found him competent to stand trial, stating that amnesia does not constitute incompetency per se when the appellant has a present ability to follow the course of the proceedings and discuss them rationally.
Issue: Is it a denial of due process or of the right to effective assistance of counsel to try a defendant suffering from amnesia?
Holding: The court should consider the following factors when determining whether the defendant’s memory loss will deprive them of a fair trial and effective assistance of counsel (per the Fifth and Sixth Amendments)
- ) The extent to which the amnesia affected the defendant’s ability to assist
- ) The extent to which the amnesia affected the defendant’s ability to testify in his own behalf
- ) The extent to which the evidence could be extrinsically reconstructed in view of the defendant’s amnesia
- ) The extent to which the government assisted the defendant and counsel in that reconstruction
- ) The strength of the prosecution’s case. Most important here is whether the government’s case “is such as to negate all reasonable hypotheses of innocence”
- ) Any other facts and circumstances which would indicate whether or not the defendant had a fair trial
Jackson v. Indiana (1972)
Facts:
- Theon Jackson was charged with two counts of petty theft and was found not fit to proceed because he was deaf, mute, and had an intellectual disability.
- The court stated that he would be committed until the health department could “certify his sanity to the court.”
- This was tantamount to a “life sentence” without his having been convicted of a crime as he was considered unrestorable.
Issue: Did Jackson’s commitment to the Indiana Department of Mental Health deprive him of equal protection and violate his due process rights under the 14th Amendment?
Holding: Court determined his commitment deprived him of equal protection because the law subjected him to a more lenient commitment standard and to a more stringent standard of release than those generally applicable to others not charged with criminal offenses. In effect, the law condemned Jackson to permanent institutionalization without the showing required for commitment, or the opportunity for release. The Court also held that a defendant “cannot be held more than the reasonable period of time necessary to determine whether there is a substantial probability that he will attain that capacity in the foreseeable future.”
Cooper v. Oklahoma (1996)
Facts:
- Oklahoma law presumed that a criminal defendant was competent to stand trial unless he proved his incompetence by clear and convincing evidence.
- A judge found Cooper competent on separate occasions before and during his trial for first-degree murder, despite his bizarre behavior and conflicting expert testimony on the issue.
Issue: Did the Oklahoma law, in leaving the burden to prove competence by clear and convincing evidence with the accused, violate Cooper’s 14th Amendment rights?
Holding: The Supreme Court found that Cooper should not have had the higher burden of “clear and convincing evidence” placed on him. The Court found that the 14th Amendment was violated unless the burden on Cooper was that of “preponderance of the evidence” because this represented the proper allocation of risk or error between Cooper and the prosecution.
M’Naughten
Ake v. Oklahoma
Durham v. United States
Medina v. California (1992)
Facts:
- Before Teofilo Medina’s trial for first degree murder (among other things), the California court granted his motion for a competency hearing
- The jury empaneled for the competency hearing found him competent to stand trial, and he was subsequently convicted and sentenced to death
- The California competency statute presumes competency unless it is proved by a preponderance of the evidence that the defendant is incompetent
Issue: Did the competency statute’s burden of proof and presumption provision violate Medina’s right to due process?
Holding: The Due Process Clause permits a State to require that a defendant claiming incompetence to stand trial bear the burden of providing so by a preponderance of the evidence. The Court also determined that the State’s allocution of the burden of proof to the defendant did not transgress any recognized principle of “fundamental fairness” in operation.
Faretta v. California (1975)
Facts:
- Anthony Faretta was charged with grand theft and filed a request to represent himself.
- The judge initially accepted but later called him back to question him about his knowledge of the hearsay rule and other court procedures.
- Based on his responses, the judged determined he did not intelligently and knowingly waive his right to counsel, and the judge appointed a public defender.
- He was subsequently convicted
Issue: Did the trial court judge err in ruling that Faretta had no constitutional right to represent himself?
Holding: The Supreme Court held that a defendant in a state criminal trial has the constitutional right to defend himself when he ~voluntarily and intelligently~ wants to do so. In this case, Faretta was deprived of that constitutional right. His knowledge of the hearsay rule and court procedure was irrelevant to whether he voluntarily waived his right to counsel.
Godinez v. Moran (1993)
Facts:
- Richard Moran allegedly shot and killed three people and attempted to kill himself.
- He pleaded not guilty to three counts of first-degree murder in Nevada state court.
- Following a court-ordered psychiatric examination, Moran was found competent to stand trial.
- Two-and-a-half months later, he told the court he wanted to fire his attorney and change his pleas to guilty. He also said he wanted to prevent anyone from introducing any favorable evidence.
- The judge questioned him but ultimately accepted his waiver of his right to counsel and the guilty pleas. He was subsequently sentenced to death.
- After sentencing, Moran claimed he was mentally incompetent to represent himself and sought post-conviction relief in state court.
Issue: Does the Due Process Clause of the Fourteenth Amendment require a trial court to apply a heightened “reasoned choice” standard to determine the competency of a defendant to enter a plea of guilty or waive counsel?
Holding: The Supreme Court held that pleading guilty and waiving a right to counsel do not require a higher level of competency than standing trial. They determined there was no reason to believe waiving these rights required a higher mental capacity than waiving other constitutional rights. Additionally, a higher standard is not necessary in order to ensure that a defendant is competent to represent himself, because the ability to do so has no bearing upon his competence to choose self representation.
