Case Law GREEN Cards ONLY Flashcards
Hall v. Florida (2014)
Freddie Hall and an accomplice beat, raped, and murdered a 21-year-old newlywed and murdered a sheriff’s deputy. He was convicted, faced the death penalty. He had intellectual disability (FSIQ=71). The Court found that the FL statute identifying an IQ threshold of FSIQ=70 was unconstitutional. It goes against standard medical practice by considering an IQ score conclusory and interprets it as factual and exact without consideration of the imprecision inherent in the measurement.
Cooper v. Oklahoma (1996) SCOTUS
Byron Cooper was charged with killing an 86-year-old during the commission of a burglary. CST was evaluated five times based on the “clear and convincing” standard. Convicted, sentenced to death. SCOTUS established the “preponderance of the evidence” standard for CST. Clear and convincing standard was too high and violated due process, as an erroneous determination had “dire consequences” for the defendant and modest consequences for the state.
Ake v. Oklahoma (1985) SCOTUS
Glen Burton Ake was charged with murdering a couple and wounding their children. At arraignment, the judge ordered a CST evaluation due to his bizarre behavior. He was deemed delusional and diagnosed with paranoid schizophrenia. CST restored, and defense counsel later requested court-appointed psychiatrist for purposes of CR evaluation, which the Court refused. Ake had burden of proof for CR. SCOTUS found that an indigent defendant has the right to receive the assistance of a psychiatric expert, at the state’s expense, when they have made a preliminary showing that his sanity t the time of the alleged offense is likely to be a significant factor at trial.
Medina v. California (1992) SCOTUS
Teofilo Medina Jr. stole a gun and went on a several-week-long crime spree. CA statute placed the burden of CST on the party raising the issue. SCOTUS said it is not unconstitutional to place the burden on the defendant (or party raising the issue of incompetence), so long as they are afforded an opportunity to demonstrate incompetence. SCOTUS also reaffirmed the CST standard as “preponderance of the evidence,” or “more likely than not.”
*Note: per LB, State v. Curtis indicates that if a case is contested in MN (the defendant says incompetent and the prosecutor says competent), the burden of proof rests on the prosecutor to prove competence. If competency is disputed and the proof of competency is absent, the Court must find the defendant incompetent to proceed. This case affirmed an earlier ruling in Gilpat.
Sell v. U.S. (2003) SCOTUS
Charles sell, a dentist, was charged with fraud and found incompetent due to unmedicated psychotic symptoms. SCOTUS ruled that a defendant can be medicated against their will (even if they are non-dangerous) for the purposes of competency restoration ONLY IF four criteria are met: 1) important government interests are served by CST (e.g., if dangerous to self/others, if incompetent to make treatment decisions, or if charges are “serious”), 2) medications are substantially likely to significantly further those interests (and side effects will not interfere with CST), 3) less intrusive interventions are unlikely to benefit, and 4) meds are also in the best medical interest of the patient.
Colorado v. Connelly (1986) SCOTUS
Francis Connelly randomly approached a Denver police officer and confessed to murder. He was advised of his Miranda rights, then said the “voice of God” told him to fly to Boston and confess to the murder. SCOTUS said coercive police tactics are necessary to establish a confession was not voluntary. Mental illness in a defendant, in and of itself, does not provide a basis to conclude the confession was coerced or was an improper waiver of rights. A defendant can be convicted on the basis of a confession prompted by severe mental illness.
Faretta v. California (1975) SCOTUS
Anthony Faretta was charged with grand theft and asked to represent himself. This case set the standard for a defendant’s competency to waive their right to counsel. Waiver of counsel must be done “knowingly and intelligently” and must be “literate, competent, and understanding…voluntarily exercising informed free will.” A defendant is not incompetent simply because he doesn’t understand some or even many of the technical, legal issues. A defendant has the right to self-representation by the Sixth amendment.
Godinez v. Moran (1993) SCOTUS
Richard Moran entered the Red Pearl Saloon, shot the bartender and a patron four times. Nine days later, he shot his ex-wife five times, then himself. He summoned police to his bedside and confessed. He was found competent; two months later, he wanted to discharge his attorney and plead guilty. The Court held that the standard for pleading guilty and waiving right to counsel is the same as CST. The waiver must be done “knowingly and voluntarily.” The sum total decisions made by a defendant during trial are no less complicated than those in pleading guilty.
Indiana v. Edwards (2008) SCOTUS
Ahmad Edwards had schizophrenia. He tried to steal a pair of shoes from a department store and, when caught, drew a gun and shot at a security officer. He was charged with attempted murder, found incompetent and ordered to the hospital for treatment. As trial began, he asked to represent himself. The standard for CST is not linked to the standard for competency to represent oneself (pro se). They are separate issues. CST with an attorney is not the same as competency to stand trial without an attorney or while representing oneself. The standard for CST presumes a defendant will have a lawyer to assist him at trial. A state may therefore require an otherwise-competent defendant to proceed to trial with the assistance of counsel.
Miranda v. Arizona (1966) SCOTUS
Miranda and three other cases were reviewed together. In each case, the defendant was held in police custody and questioned without being given a full and effective warning of their Constitutional rights. The Court ruled that statements made by a defendant can be admissible at trial only if the prosecution can show the defendant was informed of their right to counsel and right against self-incrimination and that they understood these rights and voluntarily waived them. “The person in custody must, prior to interrogation, be clearly informed that he has the right to remain silent, and that anything he says will be used against him in court; he must be clearly informed that he has the right to consult with a lawyer and to have the lawyer with him during interrogation, and that, if he is indigent, a lawyer will be appointed to represent him.” The Court also said interrogation must immediately cease when a defendant invokes his right to counsel, and an attorney must be provided.
North Carolina v. Alford (1970) SCOTUS
Henry Alford was charged with capital murder. He told the Court he was innocent but accepted a guilty plea in order to avoid the possibility of a death sentence if convicted of capital murder. The Court ruled a guilty plea can be accepted from a defendant claiming innocence if 1) the plea is a product of free and rational choice and 2) evidence strongly suggests guilt. This is not a violation of defendant rights and is no different than pleading nolo contendre. Must be voluntary, knowing, and understanding. Known as al Alford plea.
U.S. v. Marble (1991) DC Court of Appeals
Ronald Marble was charged with bank robbery (via a note). He declined the insanity defense, was found CST. The Court refused to impose the insanity defense against his will. The Court ruled that a competent defendant must be allowed to accept CR, even when he may have been mentally ill at the time. The Court can only raise the insanity defense sua sponte if the defendant is incapable of making an intelligent and voluntary decision to do so. This case refutes Whalem and supports Faretta and Alford.
Powell v. Texas (1989)
The Sixth Amendment’s right to counsel requires defendants or their attorneys to be notified that the evaluation will encompass the issue of future dangerousness. The pursuit of an insanity defense does not constitute a waiver of this notification. However, it is unconstitutional for the state to use evidence from an insanity evaluation to determine dangerousness without the defendant knowing this purpose of the evaluation.
