Godinez v. Moran
Godinez v. Moran | |
---|---|
Holding | |
The competency standard for pleading guilty is the same as the competency standard for standing trial | |
Court membership | |
| |
Case opinions | |
Majority | Thomas, joined by Rehnquist, White, O'Connor, Souter; Scalia, Kennedy (Parts I, II-B, III) |
Concurrence | Kennedy (in part and in judgment), joined by Scalia |
Dissent | Blackmun, joined by Stevens |
Laws applied | |
U.S. Const. amend. XIV |
Godinez v. Moran, 509 U.S. 389 (1993), was a
Circumstances
On August 2, 1984, Richard Allen Moran entered the Red Pearl Saloon in
He was charged with three counts of first-degree murder, but pleaded not guilty. Two court-ordered psychiatrists concluded that he was competent to stand trial, although both noted he was depressed.[3]
The prosecution sought the
Appeals
Moran's appeal to the
Moran petitioned the Supreme Court on a writ of certiorari.
Decision
In a split decision (7–2), the Court found that competency to stand trial and competency to plead guilty were equivalent competencies. In other words, if a person was found competent for one, the person was automatically competent for the second. Further, the court held that a person who is competent to stand trial is also competent to waive an attorney and proceed
As Justice Kennedy stated in his concurring opinion: "At common law, therefore, no attempt was made to apply different competency standards to different stages of criminal proceedings or to the variety of decisions that a defendant must make during the course of those proceedings."[5] Further, the Due Process Clause "does not mandate different standards of competency at various stages of or for different decisions made during the criminal proceedings."[5]
Significance
The court appears to be moving toward a single standard of competency to be applied throughout criminal proceedings. The court finds nothing in case law to the contrary. "[S]etting out varying competency standards for each decision and stage of a criminal proceeding would disrupt the orderly course of trial and, from the standpoint of all parties, prove unworkable both at trial and on appellate review."[1]
As Justice Kennedy notes, this holding in Godinez v. Moran may seem harsh in equating all competencies as essentially equal. However, there are limitations noted in a careful reading of the decision. One is that the Court emphasized that competence to waive legal counsel alone does not make a waiver of counsel valid. The trial judge must determine if the waiver is "voluntary" and "intelligent".[6]
Further, in a decision, McKaskle v. Wiggins (1984), the Court held that even if the defendant successfully waives counsel, the court can provide a "standby counsel" if the pro se defendant has actual control over the presentation of the case to the jury, and the jury retains the belief the defendant is in charge of his own case.[3]
Implications for evaluation
Following this decision, a forensic clinician conducting a competency evaluation for competency to stand trial, should also include an evaluation of competency to waive counsel.[3]
Subsequent developments
Moran was executed by lethal injection on March 30, 1996.[7]
See also
- List of United States Supreme Court cases, volume 509
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
- Competency evaluation
- List of criminal competencies
- Indiana v. Edwards
General:
- Capital punishment in Nevada
- Capital punishment in the United States
- List of people executed in Nevada
Footnotes
- ^ a b c d Godinez v. Moran, 509 U.S. 389 (1993). This article incorporates public domain material from this U.S government document.
- ^ "Landmark Cases - Salvador GODINEZ, warden, v. Richard MORAN". Psychiatry and the Law. Archived from the original on May 14, 2008. Retrieved January 5, 2008.
- ^ ISBN 1-57230-236-4.
- 9th Cir.1992).
- ^ a b Godinez, 509 U.S. at 407 (Kennedy, J., concurring).
- ISBN 978-0-8377-3025-7. Retrieved January 5, 2008.
- ^ "Man who killed 3 while high on drugs executed in Nevada". Deseret News. March 31, 1996.
Further reading
- Perlin, Michael L. (1996). "'Dignity was the First to Leave': Godinez v. Moran, Colin Ferguson, and the Trial of Mentally Disabled Criminal Defendants". Behavioral Sciences & the Law. 14 (1): 61–81. .
External links
- Text of Godinez v. Moran, 509 U.S. 389 (1993) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio) Oklahoma State Courts Network
- Competency to Stand Trial