Competency Flashcards
Dusky v. United States (1959)
SCOTUS established standards for CST: sufficient present ability to consult with an attorney with a reasonable degree of rational understanding & rational and factual understanding of the proceedings against him
capacity not willingness
Wilson v. United States (1968)
amnesia alone is not grounds for IST
Ake v. Oklahoma (1985)
Indigent defendants must be provided psychiatric expertise at sentencing in a capital case in which mental illness or dangerousness is at issue
Pate v. Robinson (1966)
A trial judge must order an inquiry into competency if a “bona fide doubt” exists about CST
Drope v. Missouri (1975)
IST responsibility expanded to include all parties
Jackson v. Indiana (1972)
SCOTUS ruled that individuals found IST cannot be held indefinitely if there is no real chance of recovering competency
confinement for IST must address competency restoration, not just warehousing; and if competency cannot be expected within a reasonable period of time, the defendant must be released or civilly commitment (states vary from 1 to 5 years)
Estelle v. Smith (1981)
Failure to notify defense of the CST evaluation violated rights
Cooper v. OK (1996)
preponderance of the evidence as standard in competency cases
Medina v. CA (1992)
burden of proof falls upon the party making that assertion, typically defendant
affirmed preponderance of the evidence as standard for CST
US v. Duhon (2000)
competency restoration cannot merely take the form of rote memorization of courtroom trivia
Riggins v. Nevada (1992)
SCOTUS ruled that rights were violated with forced meds; meds were forced so that he was appropriate, not to mitigate danger, and that it could have been replaced with less intrusive method; prohibited medication to render one competent
Sell v. United States (2003)
SCOTUS ruled that an inmate could be involuntarily medicated under 4 conditions
(1) The individual facts of the case suggest that important governmental interests are served by getting the defendant competent and proceeding to trial.
(2) The forced medication is substantially likely to significantly further those state interests.
(3) Any less intrusive interventions are unlikely to provide the same benefits.
(4) The medication is also in the best medical interest of the defendant.
Court urged that other rationales be used (dangerousness)
US v. Greer (1998)
Def obstructed justice by malingering incompetence and allowed a sentence enhancement
Seiling v. Eyman (1973)
competence to plead guilty higher than CST (overruled by Godinez v. Moran)
Colorado v. Connelly (1986)
Mental illness in a defendant, in and of itself, does not provide a basis to conclude that the confession was coerced or that there was improper waiver of right; individuals can be convicted of crimes on the basis of confessions prompted by mental illness