LANDMARK CASES A Flashcards
Addington v. Texas (SCOTUS 1979) FOTC / Issue
- Addington numerous psych hosps
- Mother petitioned for indefinite to state hospital due to assault by threat
- Trial SOP: CACE. Found MI and committable.
- Addington argued should’ve BARD.
- TX COA reversed, agreed Addington
- TX SC reversed, reinstating judgment & concluding POTE
- Appealed SCOTUS
ISSUE: What SOP for civil commitment req’d by 14th A ?
Addington v. Texas (SCOTUS 1979) H&R
H: CACE by state is constitutional min req. (Commitment affirmed)
R: Bc individual liberty rights (greater concer), must be higher than other civil cases (POTE). But BARD inappropriate bc psychiatric dx uncertain so unreasonable burden on state
Addington v. Texas (SCOTUS 1979) 4 Reasons Standard Less than BARD
- Commitment not punitive
- Periodic review/possible release
- Risk of non-commitment not equivalent to failure to incarcerate; non-committed MI not wholly free outside hosp
- State has legitimate interest in care of MI persons via parens patriae
Addington v. Texas (SCOTUS 1979) Famous Quote
“One who is suffering from a debilitating illness and is in need of tx is neither wholly at liberty nor free of stigma.”
Ake v. Oklahoma (SCOTUS 1985) FOTC
- Ake charged murdering couple/wounding children
- Bizarre behavior @ arraignment, judge ordered psych eval
- Found IST, committed, started antipsychs and CST 6wks later
- No NGRI eval. Atty asked court, judge denied.
- Ake presented NGRI case, called CST evaluators
- Since hadn’t eval’d that Q, couldn’t provide expert test, court denied
- Judge instructed jury to presume sane until presented evidence
- Jury sentenced to death
- OK COA upheld court’s denial
Ake v. Oklahoma (SCOTUS 1985) H (2)
- State must provide indigent crim defendant w/ free psych assistance in preparing NGRI defense if seriously in Q (case reversed, new trial ordered)
- If state seeks death penalty on ground of danger to society, indigent def constitutionally entitled to psych assistance to rebut and eval/testify on future dangerousness
Ake v. Oklahoma (SCOTUS 1985) Reasoning (Reason & 2 Notes/Caveat)
- Extension of indigent defendant entitled to assistance of counsel at trial, state must take steps to assure defendant has opportunity to prepare defense (14th A).
- Psych not only to eval, but also “assist in evaluation, preparation, and presentation of the defense”
- Just 1 psych, def doesn’t get to choose
Ake v. Oklahoma (SCOTUS 1985) 3 Relevant Factors Determining Type of Assistance Required by State
- Defendant’s stake in the proceeding, “almost uniquely compelling” when life/liberty at risk
- State’s interest
- Value of assistance sough, risk of error if denied
Allen v. Illinois (SCOTUS 1986) FOTC
- Allen charged w/ sex assault crimes
- State moved to declare him Sexually Dangerous Person, which means MI + sex offense propensities, more likely towards acts of sex assault/molestation
- Trial court ordered Allen to submit to 2 psych evals, & testimony allowed
- Allen objected and appealed they had elicited information violating privilege against self-incrimination
- IL COA reversed, relying Estelle v. Smith (can’t force submission psych eval for sentencing)
- IL SC reversed COA saying 5th A not available bc Sexually Dangerous Person Proceedings Civil in Nature
Allen v. Illinois (SCOTUS 1986) H (1) and R (2)
H: Upheld IL SC. Proceedings under Sexually Dangerous Persons Act not criminal so no 5th A protections against self incrimination
R: TREATMENT not PUNISHMENT.
- Just bc requires crime, has some safeguards, and can lead to confinement, doesn’t mean criminal
Allen v. Illinois (SCOTUS 1986)
VS. Gault
Allen repudiates Gault’s suggestion that 5th A should apply whenever proceedings may lead to loss of liberty, rather sole question is tx or punishment
Allen v. Illinois (SCOTUS 1986) Dissent (2)
- Stevens (4-judge minority) said proceedings should be viewed as criminal w/r/t 5th A bc of serious consequences of liberty curtailment + stigma of Sexually Dangerous Person.
- Even if a criminal statute said goal was tx, obvious 5th A would apply
Application of President and Directors of Georgetown College (DC COA 1964) FOTC
- Mrs. Jessie Jones 25 Jehovah’s Witness acute GI bleed, lost 2/3 vol
- Pt/husband declined xfusion/religious. Surgeon declined bc risk too great w/o xfusion
- Hosp atty applied Dist. Co, who refused bc “no pending case or controversy.”
- DENIED petition brought to COA for single-justice overruling.
- Judge J. Skelly Wright came to hosp, spoke w/ husband who refused by said if it were ordered, wouldn’t be their responsibility
- Spoke w/ Mrs. Jones (barely could), said “Against my will” but similarly if he ordered, she wouldn’t refuse
Application of President and Directors of Georgetown College (DC COA 1964) H & Reasoning of Judge Wright (Legal Controversy + 4 Points)
H: Ordered xfusion given
R: Legal controversy bc had sought care, placing legal responsibility on hospital, and then refusal placed hospital in legal dilemma
1. Right for court order tx essentially of sick child, Mrs. Jones was in extremis and hardly compos mentis, unable to decide for self
2. Felt responsibility to her own 7m/o child
3. Religious views prevented consent but not actual reception. So court order would resolve
4. No time or reflection/legal research
Application of President and Directors of Georgetown College (DC COA 1964) COA (Course, Result, and 4 Opinions)
- Joneses filed an Appeal for “en banc” (whole bench instead of single justic) rehearing
- Appeal denied w/ 4 diff opinions:
1. Order for tx had expired, so controversy moot
2. No justiciable controversy in 1st place, didn’t think it belonged in legal court
3. Case should be stricken so no precedent to be followed in future
4. Burger: No legal controversy bc waiver signed releasing hosp from liability 2/2 xfusion refusal. Hospital created legal problem out of moral (“Mr. and Mrs. Jones have the right to be left alone by court system”)
