LANDMARK CASES I-K Flashcards
Ibn-Tamas v. United States (DC COA 1979) FOTC
- Ibn-Tamas conv 2deg murder bc shot husband (NSGY) to death
- Substantial evidence victim had been violent towards her, including AM of shooting
- Conflicting testimony about extent of self-defense
- Court excluded psychologist (Dr. Walker’s) testimony as expert on “battered women”
- Was going to 1) describe phenomenon and 2) Give opinion about how Ibn-Tamas corresponded it
- Defense said relevant bc would help jury appraise credibility that she had perceived self is such imminent danger that shot in self-defense
- Trial court excluded bc would “invade province of the jury” as sole judges of facts and triers of credibility
Ibn-Tamas v. United States (DC COA 1979) H
H:
- COA erred in precluding psychologist testimony bc would not invade pronvince of jury, either on ultimate issue or “beyond the ken” basis. Remanded to gather more evidence on methodology
Ibn-Tamas v. United States (DC COA 1979) R (2 Ways Expert Preempts Jury’s Function, 3-Fold Test for Admissibility as Beyond the Ken, General Standard Cited for Expert Admissibility)
Preempt Jury Function:
1. Testify to Ultimate Issue
2. Testify on matters the jury just as competent to consider, “the matter is not beyond the ken of the average layman.”
3-Fold Test for Admissibility as Beyond the Ken:
1. Subject matter must be so scientific as beyond ken of average layman
2. Expert must have sufficient knowledge/skill/xp in that field so that testimony will aid truth finding
3. The specific art must permit reasonable opinion by an expert
GENERAL: Cited Frye test. SCOTUS said didn’t have sufficient information on general acceptance of battered woman methodology, so remanded
Ibn-Tamas v. United States (DC COA 1979) vs. Daubert
Ibn-Tamas superseded by Daubert in those jurisdictions that use Daubert
Indiana v. Edwards (SCOTUS 2008) FOTC
- Edwards attempted to steal shoes, then fired gun at security guard and wounded bystander
- Underwent 3x CST proceedings and 2 self-representation requests
- Committed to state hospitals as IST, occasionally some improvement
- 5 years later, right before trial, asked again for continuance to proceed pro se
- Court refused, went to trial with atty
- Conv of criminal recklessness and theft, no verdict on other charges
- Year later, court going to retry on other charges
- Again requested to represent self
- Court still found schiz and CST, but said not competent to represent self
- Represented by counsel, convicted on other charges
- Appealed, stating court’s refusal of pro se violated 6th A
- IN SC found state required to allow Edwards to represent self
- Indiana petitioned to SCOTUS
Indiana v. Edwards (SCOTUS 2008) H & R (6 - 2 Godinez, 1 other case, 1/3 Other Risks, and Ultimate Decision on IN SC Ruling)
H: Const permits State to limit right to self-representation by requiring rep by counsel at trial if defendant lacks mental capacity to conduct trial defense unless represented
R:
- Godinez asserted that competence to waive counsel =/= competence to represent self
- Said both this and Godinez fell in gray area b/w Dusky and higher standard for legal purposes; constitution doesn’t require absolute right to self-representation for gray-area defs
- Cited Faretta which limited, such as when exhibits “mental derangement” that precludes right to fair trial
- Also noted dignity not affirmed if lacks capacity, could cause humiliating spectacle, and lead to unfair trial
- IN’s proposed standard where def “cannot communicate coherently with the court or a jury” not endorsed, bc unclear how would work
- So vacated and remanded
Indiana v. Edwards (SCOTUS 2008) APA/AAPL Amicus Brief
Court agreed with this stating MI can impair certain capacities but not others
Indiana v. Edwards (SCOTUS 2008) Dissent
Argued new competence to represent self w/o clarifying definition of its components allows states to substitute own perception and strip MI defs of their right to pro se
Irving Independent School District v. Tatro (SCOTUS 1984) FOTC
- Tatro 8F w/ spina bifida: ortho/speech impairments, but also neurogenic bladder req Q3-4h CIC
- Can be performed by lay person in a few minutes w/ < 1h training
- School district received fed funding under Education for All Handicapped Children Act (EAHCA), requiring providing “free appropriate public education” w/ “related services”
- School declined to provide, parents sued under EAHCA and S.504 R.A. for excluding benefits from program under federal aid
- Fed Distr Co denied request for preliminary injunction
- COA reversed, Distr Co found CIC was related service and ordered district to provide and pay compensatory damages/atty fees
- COA affirmed
Irving Independent School District v. Tatro (SCOTUS 1984) 2 Issues
- Whether EAHCA requires district to provide CICs for Tatro
- Whether S. 504 R.A. creates such obligation
Irving Independent School District v. Tatro (SCOTUS 1984) H (2) & R (Gen, 4 Limitations on Related Services to Avoid Undue Burden)
H:
- CIC “related service” under EAHCA
- S504RA inapplicable when relief available under EAHCA to remedy denial of services, so couldn’t get atty fees & such
R:
- CIC qualify bc if not available, child can’t attend/benefit, so same as entering/exiting school etc
1. Child must be handicapped
2. Services must be “necessary” for child to benefit from education
3. If need to be provided by physician, school not required to provide
4. Services, not equipment?
Jackson v. Indiana (SCOTUS 1972) FOTC
- Jackson severe ID deaf mute, mental level of preschooler
- 27y/o charged with $9 robberies
- IST, extremely unlikely to read/write/CST. Held in psych hospital
- Appeal filed claiming amounted to life sentence w/o conviction, violating 14th A, 8th A
- IN SC rejected
- Appealed SCOTUS
Jackson v. Indiana (SCOTUS 1972) H & R 5 (EP(4), Other Case, DP, Famous Quote, Add’l Req)
H: Reversed. Committed to hospital solely bc IST can’t be held more than reasonable period of time necessary to determine if substantial probability that will attain CST in foreseeable future
R:
- EP denied bc if had not been charged w/ criminal offense, commitment standard would’ve been diff, release standards more lenient, maybe diff institution w/ better care, entitled to other privileges now not
- Cited Baxstrom v. Herold which had found EP violations for convicted, and Jackson only accused
- DP violated: w/o dangerousness, can only be held for period to determine reasonable likelihood of CST, otherwise, release or commitment hearing
- Famous quote: “Due process requires that the nature and duration of commitment bear some reasonable relation to the purpose for which the individual is commmitted”
- Also req’d periodic reports not < often than Q6m
Jaffee v. Redmond (SCOTUS 1996) FOTC
- Redmond (LEO) shot/killed Allan on patrol; claimed chasing another man w/ knife and disregarded commands to drop
- Jaffee, executor of Allan’s estate, filed suit alleging violated const rights w/ excessive force
- Redmond received therapy following with LCSW. Both refused to provide access to tx notes, asserting psychotherapist-patient privilege
- Trial judge rejected, instructed to jury that Redmond’s refusal had “no legal justification” and jury could therefore presume contents unfavorable to Redmond
- Jury award 545k to Allan’s family
- COA reversed, concluding “reason and experience” compelled recognition of this privilege
- Appealed to SCOTUS
Jaffee v. Redmond (SCOTUS 1996) Issue
Is it appropriate to recognize “psychotherapist privilege” under R. 501 FRoE? “privilege of a witness shall be governed by the principles of the common law as they may be interpreted by the US courts in the light of reason and experience.”
