Other criminal competencies Flashcards
Berghuis v. Thompkins (2010)
On appeal, Thompkins argued that his confession was obtained in violation of the Fifth Amendment and that he was denied effective counsel at trial. The Sixth Circuit held that the Michigan Supreme Court’s finding that Thompkins waived his Fifth Amendment right was unreasonable because Thompkins refused to sign an acknowledgement that he had been informed of his Miranda rights and rarely made eye contact with the officer throughout the three-hour interview.
1) Did the Sixth Circuit improperly expand the Miranda rule when it held that defendant’s Fifth Amendment rights were violated?
2) Did the Sixth Circuit fail to give the state court deference when it granted habeas corpus relief with respect to defendant’s ineffective counsel argument when there was substantial evidence of the defendant’s guilt?
Yes. The Supreme Court reversed the Sixth Circuit, holding that the state court’s decision to reject Mr. Thompkins’ Miranda claim was correct.
Court reasoned that Mr. Thompkins failed to invoke his Miranda rights to remain silent and to counsel because he failed to do so “unambiguously.” Moreover, the Court reasoned that Mr. Thompkins waived his Miranda right to remain silent when he “knowingly and voluntarily” made a statement to the police. The Court further held that, even if Mr. Thompkins’ counsel was ineffective, he cannot show he was prejudiced by counsel’s deficient performance – a prerequisite to establishing that his Sixth Amendment right was violated.
Brown v. Mississippi (1936)
Confessions brought on by force
At trial, aside from confessions, there was no evidence sufficient to warrant the submission of the case to the jury. Defendants testified the confessions were false and had been procured by physical torture. The case went to jury with instructions, upon the request of defense counsel, that if the jury had reasonable doubt as to the confessions having resulted from coercion, and they were not true, they were not to be considered as evidence. Defendants were found guilty and sentenced to death.
SCOTUS reversed the judgement convicting defendants. The use of defendants’ confessions at trial was a clear denial of due process, rendering the convictions and sentences void. Defendants’ confessions that was extracted by police violence cannot be entered as evidence and violates the Due Process Clause of the 14th Amendment.
Colorado v. Connelly (1986)
Admission of mentally ill defendants’ confessions to criminal acts.
Does the constitution require a court to suppress a confession when the defendant’s mental state, at the time he confessed, interfered with his rational intellect and free will?
No. The trial court did not have grounds to suppress Connelly’s confession. Miranda v. Arizona specifically states that confessions may only be thrown out if delivered under coercion. “Coercive police activity is a necessary predicate to finding that a confession is not “voluntary” within the meaning of the Due Process Clause.” Further, the court noted that the standard of the evidence for the state in proving the waiver of Miranda Rights was willing is not clear and convincing, but preponderance of the evidence (Lego v. Twomey). Further, the notion that Mr. Connelly lacked free will at the time of his confession due to his mental state, “is a matter to which the Federal Constitution does not speak.”
Crane v. Kentucky (1986)
Reliability/voluntariness of confessions
A clerk was shot and killed during a robbery. A week later, police arrested 16-year-old Crane for his suspected participation in an unrelated robbery. According to police, Crane “out of the clear blue sky” confessed to numerous past crimes and eventually confessed to the murder. Police had no physical evidence aside from the confession. While he was being interrogated, he was kept in a small windowless room for a long period of time, was surrounded by six police officers, and repeatedly requested and was denied permission to call his mother. There were several noted discrepancies between his confession and the facts: Crane said the shooting took place during the day and he stole money from the cash register, but it took place at night, and no money was stolen.
Were Crane’s rights violated when the circumstances around his confession were excluded at trial?
Yes (unanimous). The physical and psychological environment that yielded the confession can also be of substantial relevance to the ultimate factual issue of the defendant’s guilt or innocence. Whether rooted directly in the Due Process Clause of the 14th Amendment or in the Compulsory Process or Confrontation clauses of the Sixth Amendment, the Constitution guarantees criminal defendants “a meaningful opportunity to present a complete defense. An essential component of procedural fairness is an opportunity to be heard.”
Evidence about the manner in which confession was obtained is often highly relevant to its reliability and credibility.
Dickerson v. US (2000)
The FBI and local detectives testified that Dickerson was advised of his Miranda rights, established in Miranda v. Arizona, and waived them before he made his statement. Dickerson said he was not read his Miranda warnings until after he gave his statement. After his indictment for bank robbery, Dickerson filed a motion to suppress the statement that he made on the ground that he had not received Miranda warnings before being interrogated. The government argued that even if the Miranda warnings were not read, the statement was voluntary and therefore admissible under 18 USC Section 3501, which provides that “a confession shall be admissible in evidence if it is voluntarily given.” The District Court granted Dickerson’s motion, finding that he had not been read his Miranda rights or signed a waiver until after he made his statement, but the court did not address section 3501.
Miranda, being a constitutional decision of the court, may not be in effect overruled by an act of congress…Whether or not we agree with Miranda’s reasoning and its resulting rule, were we addressing the issue in the first instance, the principles of stare decisis weigh heavily against overruling it now.” Miranda rights have become “so embedded in routine police practice to the point where the warnings have become part of our national culture.”
Miranda warnings must be read to criminal suspects, reaffirmed Miranda and declared 18 USC 3501 unconstitutional (“Miranda requires procedures that will warn a suspect in custody of his right to remain silent which will assure the suspect that the exercise of that right will be honored”). Court reiterated concern about the inherently coercive nature of custodial interrogations and the potential blurring of boundaries between voluntary and involuntary statements.
Escobedo v. Illinois (1964)
Right to counsel during police interrogations
He was not awarded his rights protected under the sixth amendment which require that people arrested are made aware of their right to speak to an attorney and their right to keep silent. “A Constitution which guarantees a defendant the aid of counsel at trial could surely vouchsafe no less to an indicted defendant under interrogation by the police in a completely extrajudicial proceeding. Anything less might deny a defendant ‘effective representation’ by counsel at the only stage when legal aid and advice would help him.” A law enforcement system that relies too much on the confession is more subject to abuse than one that depends on evidence obtained through skillful investigation.
Fare v. Michael C (1979)
Juvenile Fifth Amendment rights
Does a juvenile’s request for his probation officer trigger the Fifth Amendment privilege against self-incrimination?
A juvenile’s request for a probation officer does not invoke the Fifth Amendment protection against self-incrimination. Miranda is based on the unique role an attorney plays in the adversarial system, and a probation officer is not in a position to offer the type of legal assistance necessary to protect Fifth Amendment rights. A court must look at the totality of the circumstances in each case to determine whether a juvenile waived that right. In this case, Michael voluntarily and knowingly waived his right to remain silent, so all evidence obtained during the police questioning is admissible in court. So, testimony given by the minor accused is valid since he was informed of his rights and opportunities but refused them.
Faretta v. California (1975)
Constitutional rights and proceeding without counsel
Does a defendant in a criminal proceeding have the right to represent themselves and reject the assistance of counsel?
Yes. Defendants have the constitutional right to represent themselves in a trial. This right is implied in the sixth amendment, which outlines what a complete defense requires. If counsel is imposed, then the defendant is no longer in charge of their defense and may feel that the law is against them. A defendant might present a better case than a lawyer. Forcing counsel on a defendant could actually hurt his case and it is he who suffers the consequences. There is no evidence that the Founders intended that the right to counsel be compulsory, rather they saw it as a benefit to have counsel present. Defendants have had the right in federal courts to be able to represent themselves since the U.S. was founded. Defendants may knowingly and intelligently waive their right to counsel. Faretta was denied his constitutional right to conduct his own defense when the state would now allow him to represent himself.
Fellers v. United States (2004)
Sixth Amendment right to counsel
Were Fellers’s rights violated when he was denied the assistance of legal counsel after the initiation of formal criminal proceedings?
Yes. Acts by law enforcement officers intended to elicit incriminating information after the initiation of formal criminal proceedings violate a defendant’s Sixth Amendment rights when the defendant is denied the assistance of legal counsel. The initiation of criminal proceedings through any formal act, including the issuance of an indictment, triggers a defendant’s right to counsel. Any intentional act by the government to extract incriminating admissions in the absence of counsel violates a defendant’s Sixth Amendment rights. The Sixth Amendment right to counsel differs from the Fifth Amendment in that it may apply in any proceeding intended to elicit incriminating evidence and not just interrogations. When the indictment was issued, Fellers’s right to counsel arose. The officers clearly intended to evoke incriminating statements when they questioned Feller prior to arrest.
GODINEZ V. MORAN (1993)
Does the Due Process Clause of the Fourteenth Amendment require a trial court to apply a heightened “reasoned choice” standard to determine the competency of a defendant to enter a plea of guilty or waive counsel?
No. The Supreme Court held that pleading guilty and waiving a right to counsel do not require a higher level of competency than standing trial. There is no reason to believe waiving these rights requires a higher mental capacity than waiving other constitutional rights. Whether a defendant is able to adequately defend himself without an attorney is irrelevant to this decision.
In Re Gault (1967)
15yo had several issues (did not tell mother he was arrested, did not show petition to Gault or parents until 2 months after, had hearings without defendant). Did this violate due process?
Yes. Juveniles deserve due process just as much of adults and this violated 14th amendment rights, 6th amendment (Right to know charges against him, have an attorney)
Indiana v Edwards (2008)
Does the U.S. Constitution forbid the State from insisting a defendant have counsel if the State believes he is not competent to conduct a defense, even though he was previously found legally competent to stand trial?
No. The State is able to insist upon counsel if the State believes the defendant is not competent to conduct his own defense. Faretta does not answer the question because there was no issue related to Faretta’s competency to stand trial. Further, the Faretta decision rested upon other cases that deemed mental competency as a precondition for the right to proceed without counsel. Thus, the competency to represent oneself is not equivalent to the competency to stand trial, so Edwards’ competency to stand trial should not be the standard for determining his competency to represent himself.
Although this case is similar to Godinez v. Moran (1993), the critical difference is that Godinez v. Moran was regarding the defendant’s ability to proceed to enter his own plea, but this case is regarding a defendant’s ability to conduct trial proceedings. Additionally, the defendant’s right to represent himself at trial, if lacking in mental capacity to conduct his defense, will not “affirm [his] dignity” but rather is “likely to prove humiliating.” Finally, the court concludes that trials must appear fair to those who observe them.
JDB v. North Carolina (2011)
Does the Miranda custody analysis include consideration of a juvenile suspect’s age? Specifically, whether “a child’s age ‘would have affected how a reasonable person’ in the suspect’s position ‘would perceive his or her freedom to leave.’”
Yes. A person questioned by law enforcement officers after being “taken into custody or otherwise deprived of his freedom of action in any significant way” must be given Miranda warnings. In determining whether an individual was in custody, a court must examine all the circumstances surrounding the interrogation in determining whether there was a “formal arrest or restraint of freedom of movement of the degree associated with a formal arrest.”
A child’s age must be considered by law enforcement in determining whether Miranda warnings need to be given to children during police interrogations. “So long as a child’s age was known to the officer at the time of police questioning, or would have been objectively apparent to a reasonable officer, its inclusion in the custody analysis is consistent with the objective nature of that test…Just as police officers are competent to account for other objective circumstances that are a matter of degree such as the length of questioning or the number of officers present, so too are they competent to evaluate the effect of relative age.” “To hold… that a child’s age is never relevant to whether a suspect has been taken into custody— and thus to ignore the very real differences between children and adults— would be to deny children the full scope of the procedural safeguards that Miranda guarantees to adults.”
North Carolina v. Alford (1970)
Can a guilty plea be accepted even if the defendant is also testifying that they are innocent?
Yes. A guilty plea can be accepted by the court even if the defendant testifies that they are innocent. A plea must be viewed in light of evidence against the defendant to ensure that the guilty plea is intelligently made. There was strong evidence against the defendant for first-degree murder despite his claim of innocence and his plea was made to avoid the possibility of the death penalty. The guilty plea represented voluntary and intelligent choice among alternatives available to the defendant, especially since he had competent counsel. The court committed no constitutional error in accepting the guilty plea despite his claims of innocence.
U.S. v MARBLE (1991)
Did the district court abuse its discretion by failing to impose the insanity defense, or at the very least, did the court abuse its discretion by failing to conduct a more comprehensive hearing on the question of whether to impose the insanity defense?
Affirmed by the United States Court of Appeals, District of Columbia Circuit. They argue that “to impose a particular defense upon an accused, in essence to force him to affirm that he is insane, makes not only appointed counsel but the defendant himself “an origin of the state.”” The Insanity Defense Reform Act of 1984 made insanity an affirmative defense in the federal courts, and as a result, there was no additional burden of proof on the Government prosecutor. Furthermore, it is no longer wrong to convict a competent mentally ill criminal because there are standards to govern the mentally ill’s confinement and treatment. The court declared that “a district court must allow a competent defendant to accept responsibility for a crime committed when he may have been suffering from a mental disease.”
