Cooper v. Oklahoma
Encyclopedia
Cooper v. Oklahoma, was a United States Supreme Court case in which the Court reversed an Oklahoma
court decision holding that a defendant
is presumed to be competent to stand trial
unless he proves otherwise by the second highest legal standard of proof, that of clear and convincing evidence, ruling that to be unconstitutional. The court said the defendant's Fourteenth Amendment
rights to due process
were violated.
In this case, the defendant's ability to understand the charge
s against him and his ability to assist in his own defense
was challenged on five separate occasions before and during his trial
and sentencing
for capital murder, but the trial judge ruled he was competent to stand trial because he did not meet Oklahoma's high standard of proof.
of an 86-year-old man while in the course of committing burglary
. Both before and during his trial, the question of his competency to stand trial
was raised five times. The first time the question arose, the trial judge relied on the opinion of a state psychologist
in determining to commit
the defendant to a state psychiatric hospital
for three months of treatment. Upon Cooper's return, the trial judge heard testimony
from two state psychologists regarding Cooper's competence, but as these experts
disagreed over whether Cooper was competent to stand trial, the judge decided to rule against Cooper and ordered the trial to proceed. After the pretrial hearing was completed, the defense attorney raised the issue of Cooper's competence a third time, telling the court that Cooper's behavior was "odd" and that he refused to communicate with his attorney. The attorney said that it could be a serious matter "if he's not faking
". However, the judge declined to review his earlier decision that Cooper was competent to proceed.
On the first day of trial, Cooper's bizarre behavior (such as fleeing from his defense attorney, refusing to change his prison
clothes because regular clothes "burned" him, and talking to himself while in the fetal position
) induced the court to conduct a further competency hearing. This time the trial judge observed Cooper and heard testimony from people including lay witness
es, defendant Cooper, and a third psychologist who concluded that Cooper was incompetent. While expressing his uncertainty and not disagreeing with the psychologist, the judge ruled against Cooper and ordered the trial to proceed, finally opining:
The trial proceeded with Cooper continuing to act in a bizarre manner and refusing to be near his attorney. Cooper was convicted of first degree murder, and during the sentencing phase of the trial the history of Cooper's childhood abuse
was recounted. Finally the defense attorney pleaded for either a mistrial or further evaluation into Cooper's competence, describing Cooper's courtroom behavior:
The court summarily denied
the motion. Cooper received the death penalty
after the jury recommended death.
Cooper appealed, and the Oklahoma Court of Criminal Appeals
affirmed both the conviction and the sentence. Cooper appealed to the Supreme Court on a writ
of certiorari
.
, increasing the possibility of error to a level "incompatible with the dictates of due process
". Criminal defendants must be allowed to avoid trial if they prove incompetence by a "preponderance of the evidence."
The court used the relevant history of common law
regarding competency and the treatment of the insane and also compared Oklahoma's standards with the contemporary practices of other states, finding that only 4 of the 50 states used Oklahoma's heightened standard of proof. They concluded that this "demonstrates that the vast majority of jurisdictions remain persuaded that the heightened standard of proof imposed on the accused in Oklahoma is not necessary to vindicate the State's interest in prompt and orderly disposition of criminal cases." The court found most states uses a burden of proof far lower, or imposed no burden of proof at all, once the competency question is raised.
case law
. The court stated that no one questions the fundamental right of competency to stand trial. As established in Dusky v. United States
, a defendant has a fundamental right not to be put to trial unless he has "sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding . . . [and] a rational
as well as fact
ual understanding of the proceedings against him." A State may not proceed with a criminal trial after the defendant has demonstrated that he is more likely than not to be incompetent.
Oklahoma
Oklahoma is a state located in the South Central region of the United States of America. With an estimated 3,751,351 residents as of the 2010 census and a land area of 68,667 square miles , Oklahoma is the 28th most populous and 20th-largest state...
court decision holding that a defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
is presumed to be competent to stand trial
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
unless he proves otherwise by the second highest legal standard of proof, that of clear and convincing evidence, ruling that to be unconstitutional. The court said the defendant's Fourteenth Amendment
Fourteenth Amendment of the Constitution of Ireland
The Fourteenth Amendment of the Constitution of Ireland specified that the prohibition of abortion would not limit the right to distribute information about abortion services in foreign countries...
rights to due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
were violated.
In this case, the defendant's ability to understand the charge
Indictment
An indictment , in the common-law legal system, is a formal accusation that a person has committed a crime. In jurisdictions that maintain the concept of felonies, the serious criminal offence is a felony; jurisdictions that lack the concept of felonies often use that of an indictable offence—an...
s against him and his ability to assist in his own defense
Defense (legal)
In civil proceedings and criminal prosecutions under the common law, a defendant may raise a defense in an attempt to avoid criminal or civil liability...
was challenged on five separate occasions before and during his trial
Trial
A trial is, in the most general sense, a test, usually a test to see whether something does or does not meet a given standard.It may refer to:*Trial , the presentation of information in a formal setting, usually a court...
and sentencing
Sentence (law)
In law, a sentence forms the final explicit act of a judge-ruled process, and also the symbolic principal act connected to his function. The sentence can generally involve a decree of imprisonment, a fine and/or other punishments against a defendant convicted of a crime...
for capital murder, but the trial judge ruled he was competent to stand trial because he did not meet Oklahoma's high standard of proof.
Circumstances
Byron Keith Cooper was charged in 1989 with the murderMurder
Murder is the unlawful killing, with malice aforethought, of another human being, and generally this state of mind distinguishes murder from other forms of unlawful homicide...
of an 86-year-old man while in the course of committing burglary
Burglary
Burglary is a crime, the essence of which is illicit entry into a building for the purposes of committing an offense. Usually that offense will be theft, but most jurisdictions specify others which fall within the ambit of burglary...
. Both before and during his trial, the question of his competency to stand trial
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
was raised five times. The first time the question arose, the trial judge relied on the opinion of a state psychologist
Psychologist
Psychologist is a professional or academic title used by individuals who are either:* Clinical professionals who work with patients in a variety of therapeutic contexts .* Scientists conducting psychological research or teaching psychology in a college...
in determining to commit
Involuntary commitment
Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....
the defendant to a state psychiatric hospital
Psychiatric hospital
Psychiatric hospitals, also known as mental hospitals, are hospitals specializing in the treatment of serious mental disorders. Psychiatric hospitals vary widely in their size and grading. Some hospitals may specialise only in short-term or outpatient therapy for low-risk patients...
for three months of treatment. Upon Cooper's return, the trial judge heard testimony
Testimony
In law and in religion, testimony is a solemn attestation as to the truth of a matter. All testimonies should be well thought out and truthful. It was the custom in Ancient Rome for the men to place their right hand on a Bible when taking an oath...
from two state psychologists regarding Cooper's competence, but as these experts
Expert witness
An expert witness, professional witness or judicial expert is a witness, who by virtue of education, training, skill, or experience, is believed to have expertise and specialised knowledge in a particular subject beyond that of the average person, sufficient that others may officially and legally...
disagreed over whether Cooper was competent to stand trial, the judge decided to rule against Cooper and ordered the trial to proceed. After the pretrial hearing was completed, the defense attorney raised the issue of Cooper's competence a third time, telling the court that Cooper's behavior was "odd" and that he refused to communicate with his attorney. The attorney said that it could be a serious matter "if he's not faking
Malingering
Malingering is a medical term that refers to fabricating or exaggerating the symptoms of mental or physical disorders for a variety of "secondary gain" motives, which may include financial compensation ; avoiding school, work or military service; obtaining drugs; getting lighter criminal sentences;...
". However, the judge declined to review his earlier decision that Cooper was competent to proceed.
On the first day of trial, Cooper's bizarre behavior (such as fleeing from his defense attorney, refusing to change his prison
Prison
A prison is a place in which people are physically confined and, usually, deprived of a range of personal freedoms. Imprisonment or incarceration is a legal penalty that may be imposed by the state for the commission of a crime...
clothes because regular clothes "burned" him, and talking to himself while in the fetal position
Fetal position
Fetal position is a medical term used to describe the positioning of the body of a prenatal fetus as it develops...
) induced the court to conduct a further competency hearing. This time the trial judge observed Cooper and heard testimony from people including lay witness
Witness
A witness is someone who has firsthand knowledge about an event, or in the criminal justice systems usually a crime, through his or her senses and can help certify important considerations about the crime or event. A witness who has seen the event first hand is known as an eyewitness...
es, defendant Cooper, and a third psychologist who concluded that Cooper was incompetent. While expressing his uncertainty and not disagreeing with the psychologist, the judge ruled against Cooper and ordered the trial to proceed, finally opining:
The trial proceeded with Cooper continuing to act in a bizarre manner and refusing to be near his attorney. Cooper was convicted of first degree murder, and during the sentencing phase of the trial the history of Cooper's childhood abuse
Child abuse
Child abuse is the physical, sexual, emotional mistreatment, or neglect of a child. In the United States, the Centers for Disease Control and Prevention and the Department of Children And Families define child maltreatment as any act or series of acts of commission or omission by a parent or...
was recounted. Finally the defense attorney pleaded for either a mistrial or further evaluation into Cooper's competence, describing Cooper's courtroom behavior:
The court summarily denied
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
the motion. Cooper received the death penalty
Capital punishment in the United States
Capital punishment in the United States, in practice, applies only for aggravated murder and more rarely for felony murder. Capital punishment was a penalty at common law, for many felonies, and was enforced in all of the American colonies prior to the Declaration of Independence...
after the jury recommended death.
Cooper appealed, and the Oklahoma Court of Criminal Appeals
Oklahoma Court of Criminal Appeals
The Oklahoma Court of Criminal Appeals is one of the two highest judicial bodies in the U.S. state of Oklahoma and is part of the Oklahoma Court System, the judicial branch of the Oklahoma state government....
affirmed both the conviction and the sentence. Cooper appealed to the Supreme Court on a writ
Writ
In common law, a writ is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court...
of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Decision
In a unanimous verdict, the Supreme Court reversed the judgment and remanded the case back to the Oklahoma Court of Criminal Appeals for further consideration in light of their opinion. The Court held that the State may not proceed with a criminal trial when the defendant has demonstrated that he is more likely than not to be incompetent. Requiring a higher standard of proof, that of "clear and convincing evidence", was too high a standard of proof for a defendant to demonstrate a need for a competency evaluationCompetency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
, increasing the possibility of error to a level "incompatible with the dictates of due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
". Criminal defendants must be allowed to avoid trial if they prove incompetence by a "preponderance of the evidence."
The court used the relevant history of common law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...
regarding competency and the treatment of the insane and also compared Oklahoma's standards with the contemporary practices of other states, finding that only 4 of the 50 states used Oklahoma's heightened standard of proof. They concluded that this "demonstrates that the vast majority of jurisdictions remain persuaded that the heightened standard of proof imposed on the accused in Oklahoma is not necessary to vindicate the State's interest in prompt and orderly disposition of criminal cases." The court found most states uses a burden of proof far lower, or imposed no burden of proof at all, once the competency question is raised.
Significance
The American Academy for Psychiatry and the Law unofficially considers this decision a landmark case in competency to stand trialCompetency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
case law
Case law
In law, case law is the set of reported judicial decisions of selected appellate courts and other courts of first instance which make new interpretations of the law and, therefore, can be cited as precedents in a process known as stare decisis...
. The court stated that no one questions the fundamental right of competency to stand trial. As established in Dusky v. United States
Dusky v. United States
Dusky v. United States, , is a landmark decision affirming a defendant's right to have a competency evaluation before proceding to trial. In this case, the court outlined the basic standards for determining competency....
, a defendant has a fundamental right not to be put to trial unless he has "sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding . . . [and] a rational
Rationality
In philosophy, rationality is the exercise of reason. It is the manner in which people derive conclusions when considering things deliberately. It also refers to the conformity of one's beliefs with one's reasons for belief, or with one's actions with one's reasons for action...
as well as fact
Fact
A fact is something that has really occurred or is actually the case. The usual test for a statement of fact is verifiability, that is whether it can be shown to correspond to experience. Standard reference works are often used to check facts...
ual understanding of the proceedings against him." A State may not proceed with a criminal trial after the defendant has demonstrated that he is more likely than not to be incompetent.
See also
- List of United States Supreme Court cases, volume 517
- 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
- Drope v. MissouriDrope v. MissouriDrope v. Missouri , , is a United States Supreme Court case in which the court decided whether a trial court deprived a defendant of due process by failing to order a competency examination after he was hospitalized following an attempted suicide and as a result missed a portion of his trial for a...
(1975) - Ford v. WainwrightFord v. WainwrightFord v. Wainwright, ', was the case in which the United States Supreme Court upheld the common law rule that the insane cannot be executed; therefore the petitioner is entitled to a competency evaluation and to an evidentiary hearing in court on the question of his competency to be...
(1986)