Godinez v. Moran: Difference between revisions
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[[Category:United States Supreme Court cases of the Rehnquist Court]] |
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Revision as of 19:54, 17 October 2011
{{SCOTUSCase
Circumstances
On August 2, 1984, Richard Allan Moran entered the Red Pearl Saloon in Carson City, Nevada and shot the bartender and a customer before robbing the cash register. Nine days later he shot his ex-wife and then himself, and also unsuccessfully tried to slit his wrists. On August 13 Moran summoned the police to his hospital bedside and confessed to the killings.
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.[1]
|year= |month= |url=http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=509&invol=389 |title= Godinez, Warden v. Moran certiorari to the Unisted States Court of Appeals for the Ninth Circuit (1993) |publisher=FindLaw |accessdate=2008-01-05 }}</ref>
Moran petitioned the Supreme Court on a writ of certiorari.
Decision
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 [509 U.S. 389, 407] must make during the course of those proceedings."[2] 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."[3]
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."[3]
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".[4]
Further, in a decision, McKaskle v. Wiggins, 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.[1]
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.[1]
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
Footnotes
- ^ a b c Melton, Gary (1997). Psychological Evaluations for the Courts: A Handbook for Mental Health Professionals and Lawyers (2nd ed.). New York: The Guilford Press. pp. 156–157, 165–167. ISBN 1-57230-236-4.
- ^ "Godinez, Warden v. Moran certiorari to the Unisted States Court of Appeals for the Ninth Circuit (1993)". FindLaw. Retrieved 2008-01-05.
{{cite web}}: Cite has empty unknown parameter:|month=(help) - ^ a b "Salvador Godinez, Waden, Petitioner v. Richard Allan Moran". Cornell University Law School. Retrieved 2008-01-06.
{{cite web}}: Cite has empty unknown parameter:|month=(help) - ^ Samuel J. Brakel, Alexander D. Brooks (2001-04). Law and Psychiatry in the Criminal Justice System. Wm. S. Hein. ISBN 9780837730257. Retrieved 2008-01-05.
{{cite book}}: Check date values in:|date=(help); Cite has empty unknown parameter:|month=(help)
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. doi:10.1002/(SICI)1099-0798(199624)14:1<61::AID-BSL226>3.0.CO;2-G.
{{cite journal}}: Cite has empty unknown parameters:|month=and|coauthors=(help)
External links
- Text of Godinez v. Moran, 509 U.S. 389 (1993) is available from: Findlaw Justia
- Salvador Godinez, Warden, Petitioner v. Richard Allen Moran on writ of certiorari to the united states court of appeals for the ninth circuit
- Competency to Stand Trial
- Godinez, Warden v. Moran