Circumstances
On August 2, 1984, Richard Allen Moran entered the Red Pearl Saloon in Las Vegas, Nevada and shot the bartender and a customer before robbing the cash register. Nine days later he shot his ex-wife and then himself, and also unsuccessfully tried to slit his wrists. On August 13 Moran summoned the police to his hospital bedside and confessed to the killings.
He was charged with three counts of first-degree murder, but pleaded not guilty. Two court-ordered psychiatrists concluded that he was competent to stand trial, although both noted he was depressed. [3]
The prosecution sought the death penalty. Two months after the psychiatric evaluations, Moran stated to the court that he wished to discharge his attorneys and change his plea to guilty. He also waived his right to counsel. After his trial he was sentenced to death. Moran then sought state post conviction relief on the grounds that he was mentally incompetent to represent himself. The trial court held an evidentiary hearing and then it rejected his claim. [1]
Decision
In a split decision (7–2), the Court found that competency to stand trial and competency to plead guilty were equivalent competencies. In other words, if a person was found competent for one, the person was automatically competent for the second. Further, the court held that a person who is competent to stand trial is also competent to waive an attorney and proceed pro se. The court held that it was irrelevant if the individual represented himself inadequately. [3] (The Court later held in Indiana v. Edwards that the competency to stand trial was different from the competency to have self-representation.)
As Justice Kennedy stated in his concurring opinion: "At common law, therefore, no attempt was made to apply different competency standards to different stages of criminal proceedings or to the variety of decisions that a defendant must make during the course of those proceedings." [5] Further, the Due Process Clause "does not mandate different standards of competency at various stages of or for different decisions made during the criminal proceedings." [5]
Significance
The court appears to be moving toward a single standard of competency to be applied throughout criminal proceedings. The court finds nothing in case law to the contrary. "[S]etting out varying competency standards for each decision and stage of a criminal proceeding would disrupt the orderly course of trial and, from the standpoint of all parties, prove unworkable both at trial and on appellate review." [1]
As Justice Kennedy notes, this holding in Godinez v. Moran may seem harsh in equating all competencies as essentially equal. However, there are limitations noted in a careful reading of the decision. One is that the Court emphasized that competence to waive legal counsel alone does not make a waiver of counsel valid. The trial judge must determine if the waiver is "voluntary" and "intelligent". [6]
Further, in a decision, McKaskle v. Wiggins (1984), the Court held that even if the defendant successfully waives counsel, the court can provide a "standby counsel" if the pro se defendant has actual control over the presentation of the case to the jury, and the jury retains the belief the defendant is in charge of his own case. [3]
The insanity defense, also known as the mental disorder defense, is an affirmative defense by excuse in a criminal case, arguing that the defendant is not responsible for their actions due to a psychiatric disease at the time of the criminal act. This is contrasted with an excuse of provocation, in which the defendant is responsible, but the responsibility is lessened due to a temporary mental state. It is also contrasted with the justification of self defense or with the mitigation of imperfect self-defense. The insanity defense is also contrasted with a finding that a defendant cannot stand trial in a criminal case because a mental disease prevents them from effectively assisting counsel, from a civil finding in trusts and estates where a will is nullified because it was made when a mental disorder prevented a testator from recognizing the natural objects of their bounty, and from involuntary civil commitment to a mental institution, when anyone is found to be gravely disabled or to be a danger to themself or to others.
In law, a plea is a defendant's response to a criminal charge. A defendant may plead guilty or not guilty. Depending on jurisdiction, additional pleas may be available, including nolo contendere, no case to answer, or an Alford plea.
The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied all but one of this amendment's protections to the states through the Due Process Clause of the Fourteenth Amendment.
Forensic psychiatry is a subspeciality of psychiatry and is related to criminology. It encompasses the interface between law and psychiatry. According to the American Academy of Psychiatry and the Law, it is defined as "a subspecialty of psychiatry in which scientific and clinical expertise is applied in legal contexts involving civil, criminal, correctional, regulatory, or legislative matters, and in specialized clinical consultations in areas such as risk assessment or employment." A forensic psychiatrist provides services – such as determination of competency to stand trial – to a court of law to facilitate the adjudicative process and provide treatment, such as medications and psychotherapy, to criminals.
In United States and Canadian law, competence concerns the mental capacity of an individual to participate in legal proceedings or transactions, and the mental condition a person must have to be responsible for his or her decisions or acts. Competence is an attribute that is decision-specific. Depending on various factors which typically revolve around mental function integrity, an individual may or may not be competent to make a particular medical decision, a particular contractual agreement, to execute an effective deed to real property, or to execute a will having certain terms.
Faretta v. California, 422 U.S. 806 (1975), was a case in which the Supreme Court of the United States held that criminal defendants have a constitutional right to refuse counsel and represent themselves in state criminal proceedings.
Panetti v. Quarterman, 551 U.S. 930 (2007), is a decision by the Supreme Court of the United States, ruling that criminal defendants sentenced to death may not be executed if they do not understand the reason for their imminent execution, and that once the state has set an execution date death-row inmates may litigate their competency to be executed in habeas corpus proceedings. This decision reaffirmed the Court's prior holdings in Ford v. Wainwright, and Stewart v. Martinez-Villareal.
Sell v. United States, 539 U.S. 166 (2003), is a decision in which the United States Supreme Court imposed stringent limits on the right of a lower court to order the forcible administration of antipsychotic medication to a criminal defendant who had been determined to be incompetent to stand trial for the sole purpose of making them competent and able to be tried. Specifically, the court held that lower courts could do so only under limited circumstances in which specified criteria had been met. In the case of Charles Sell, since the lower court had failed to determine that all the appropriate criteria for court-ordered forcible treatment had been met, the order to forcibly medicate the defendant was reversed.
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process.
Dusky v. United States, 362 U.S. 402 (1960), was a landmark United States Supreme Court case in which the Court affirmed a defendant's right to have a competency evaluation before proceeding to trial. The Court outlined the basic standards for determining competency.
United States v. Binion, 132 F. App'x 89, is a case in which the United States Court of Appeals for the Eighth Circuit applied two recent U.S. Supreme Court decisions, United States v. Booker and United States v. Fanfan, in upholding the sentencing decision by the trial court, the United States District Court for the Eastern District of Missouri.
Wiggins v. Smith, 539 U.S. 510 (2003), is a case in which the United States Supreme Court spelled out standards for "effectiveness" in the constitutional right to legal counsel guaranteed by the Sixth Amendment. Previously the court had determined that the Sixth Amendment included the right to "effective assistance" of legal counsel, but it did not specify what constitutes "effective", thus leaving the standards for effectiveness vague. In Wiggins v. Smith, the court set forth the American Bar Association Guidelines for the Appointment and Performance of Defense Counsel in Death Penalty Cases Guideline 11.8.6.(1989), as a specific guideline by which to measure effectiveness and competence of legal counsel.
Frendak v. United States, 408 A.2d 364 is a landmark case in which District of Columbia Court of Appeals decided that a judge could not impose an insanity defense over the defendant's objections.
Drope v. Missouri, 420 U.S. 162 (1975), was a United States Supreme Court case in which the Court held a Missouri trial court deprived a defendant of due process by failing to order a competency examination after he was hospitalized following an attempted suicide and as a result missed a portion of his trial for a capital offense.
Cooper v. Oklahoma, 517 U.S. 348 (1996), was a United States Supreme Court case in which the Court reversed an Oklahoma court decision holding that a defendant is presumed to be competent to stand trial unless he proves otherwise by the second highest legal standard of proof, that of clear and convincing evidence, ruling that to be unconstitutional. The court said the defendant's Fourteenth Amendment rights to due process were violated.
Indiana v. Edwards, 554 U.S. 164 (2008), was a United States Supreme Court case in which the Court held that the standard for competency to stand trial was not linked to the standard for competency to represent oneself.
United States federal laws governing offenders with mental diseases or defects provide for the evaluation and handling of defendants who are suspected of having mental diseases or defects. The laws were completely revamped by the Insanity Defense Reform Act in the wake of the John Hinckley Jr. verdict.
The United States Constitution contains several provisions regarding the law of criminal procedure.
The Assistance of Counsel Clause of the Sixth Amendment to the United States Constitution provides: "In all criminal prosecutions, the accused shall enjoy the right...to have the Assistance of Counsel for his defence."
