US CST One-Liners Flashcards
Dusky v. U.S. (1960)
“test must be whether the defendant has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding - and whether he has a rational as well factual understanding of the proceedings against him.”
Pate v. Robinson (1966)
SCOTUS: trial court’s failure to hold competency hearing when there was sufficient evidence to do so, even though not specifically requested by defense, violated due process under 14A
Wilson v. U.S. (1968)
DC COA: amnesia for the time of the crime didn’t per se render defendant IST. Instead have to consider factors case-by-case that would be able to have fair trial
Jackson v. Indiana (1972)
SCOTUS: equal protection violated when he was held to more lenient commitment standard and higher release bar than uncharged persons. Can’t hold a defendant indefinitely due to IST or else violates due process. Have to hold reasonable amount of time to determine restorability, and if not likely restorable, either civilly commit or release.
Drope v. Missouri (1975)
SCOTUS: Question of CST can be raised at any time during proceedings, not just before trial. Whenever there’s sufficient doubt for a variety of reasons.
Estelle v. Smith (1981)
SCOTUS: Smith not informed of right to remain silent + statements in CST eval could be used against him later, so statements couldn’t be used against him in sentencing phase. Violated 5A right against self-incrimination.
Godinez v. Moran (1993)
SCOTUS: If defendant CST, then competent to make all choices pertinent, such as waiving right to counsel, against testifying, against confronting accusers, etc. However, such waivers must be “knowing, intelligent, and voluntary.”
Cooper v. Oklahoma (1996)
SCOTUS: Highest burden of proof state could require was defendant prove incompetence by preponderance of evidence
Medina v. California (1992)
SCOTUS: Burden of proof on defendant claiming incompetence. No reason it should be on state to prove competence.
Riggins v. Nevada (1992)
SCOTUS: Forced administration of meds, gotta show medically appropriate, essential for sake of safety, and least intrusive means of treatment
Riggins Ommission
Said maybe to restore competence, but didn’t explicit say if solely to restore competence appropriate
Four Factors for Sell (4.3 + 1 bonus)
- Gov’t has interest in prosecuting: seriousness of charges, time served, future psychiatric confinement that would diminish risk
- Proposed medication “substantially likely” to render defendant competent w/o causing sfx that would render him unable to assist
- Least restrictive tx to restore competence
- Whether medically appropriate - in best medical interest
BONUS: Should look for other reasons first, such as dangerousness/medical necessity, as medical experts probably more suited to give appropriate judgment of that
Indiana v. Davis (2008)
SCOTUS: Holding criminal charges over permanently incompetent defendant violated due process
United States v. Dillon (1989)
6th Circuit - 1st criteria of Sell. Even though not currently dangerous otherwise, bc of seriousness of charge (threatened president), State had necessary interest in prosecuting this charge. So +invol meds.
“Substantially Likely” Standards
United States v. Gomes: 70% chance restoration
Utah v. Barzee: > 70%
