AAPL Landmark - Death Penalty Flashcards
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. Dr. James Grigson used information from a 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) 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). 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). Man sentenced to death, a mix of opinions from psychiatrists about competence to be executed. 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). 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.
Can a state involuntarily treat a death row prisoner with antipsychotic drugs to make him competent to be executed?
No.
State v. Perry (1992). In a per curiam decision, the Court vacated the lower court’s ruling without issuing an opinion. The case was remanded to the Louisiana Supreme Court for further deliberation given Washington v. Harper (1990), also a case involving involuntary medication, which had been decided after the District Court’s ruling. 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). The USSC 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). 17 y/o pushed a woman off a bridge in Missouri. The USSC agreed with the MO SC 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.
Are a “rational understanding” and a “factual awareness” necessary for a person to be found competent to be executed?
Yes.
Panetti v. Quarterman (2007). 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). The USSC reasoned that there was no constitutional right to competence for federal habeas corpus proceedings.
Does the 8th Amendment proscribe the use of outdated medical standards for determining intellectual disability in death penalty cases?
Yes. Moore v. Texas (2017). 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). 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.
Does Ake v. Oklahoma guarantee an indigent defendant access to expert psychiatric consultation at trial, and if it is relevant to sentencing?
Yes.
McWilliams v. Dunn (2017). An indigent defendant facing the death penalty must receive access to a competent psychiatrist who will conduct an appropriate examination and assist in the evaluation, preparation, and presentation of the defense, or habeas relief may be appropriate.
