Godinez v. Moran
Encyclopedia
Godinez v. Moran, 509 U.S. 389
(1993), was a landmark decision
in which the U.S. Supreme Court ruled that if a defendant was competent
to stand trial, they were automatically competent to plead guilty or waive the right to legal counsel.
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.
The prosecution sought the death penalty. Two months after the psychiatric evaluations, Moran stated to the court that he wished to discharge his attorneys and change his plea to guilty. He also waived his right to counsel. After his trial he was sentenced to death
. Moran then sought state post conviction relief on the grounds that he was mentally incompetent to represent himself. The trial court held an evidentiary hearing and then it rejected his claim.
of habeas corpus
. However, the Court of Appeals reversed this decision, concluding that due process
required the trial court to hold a hearing to "evaluate and determine" Moran's competency before accepting his decisions to waive counsel and plead guilty. It also held that the trial court erred by using the wrong legal standard. It stated that competency to waive constitutional right
s requires a higher level of mental functioning than the level of mental functioning required to stand trial. They reasoned that competence to stand trial requires only that the defendant have a rational and factual understanding of the proceedings and is capable of assisting his counsel, while competence to waive counsel or plead guilty requires that the defendant has the capacity for reasoned choice among those choices available.
Moran petition
ed the Supreme Court on a writ
of certiorari
.
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." 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."
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".
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.
for competency to stand trial, should also include an evaluation of competency to waive counsel.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1993), was a landmark decision
Landmark decision
Landmark court decisions establish new precedents that establish a significant new legal principle or concept, or otherwise substantially change the interpretation of existing law...
in which the U.S. Supreme Court ruled that if a defendant was competent
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....
to stand trial, they were automatically competent to plead guilty or waive the right to legal counsel.
Circumstances
On August 2, 1984, Richard Allan Moran entered the Red Pearl Saloon in Carson City, NevadaCarson City, Nevada
The Consolidated Municipality of Carson City is the capital of the state of Nevada. The words Consolidated Municipality refer to a series of changes in 1969 which abolished Ormsby County and merged all the settlements contained within its borders into Carson City. Since that time Carson City has...
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.
The prosecution sought the death penalty. Two months after the psychiatric evaluations, Moran stated to the court that he wished to discharge his attorneys and change his plea to guilty. He also waived his right to counsel. After his trial he was sentenced to death
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
. Moran then sought state post conviction relief on the grounds that he was mentally incompetent to represent himself. The trial court held an evidentiary hearing and then it rejected his claim.
Appeals
Moran's appeal to the Nevada Supreme Court was dismissed and a Federal District Court denied his petition for a writWrit
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 habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
. However, the Court of Appeals reversed this decision, concluding that 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...
required the trial court to hold a hearing to "evaluate and determine" Moran's competency before accepting his decisions to waive counsel and plead guilty. It also held that the trial court erred by using the wrong legal standard. It stated that competency to waive constitutional right
Constitutional right
An inalienable right is a freedom granted by a Nature or the Creator's endowment by birth , and may not be legally denied by that government.-United States:...
s requires a higher level of mental functioning than the level of mental functioning required to stand trial. They reasoned that competence to stand trial requires only that the defendant have a rational and factual understanding of the proceedings and is capable of assisting his counsel, while competence to waive counsel or plead guilty requires that the defendant has the capacity for reasoned choice among those choices available.
Moran petition
Petition
A petition is a request to do something, most commonly addressed to a government official or public entity. Petitions to a deity are a form of prayer....
ed 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 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 pro se. The court held that it was irrelevant if the individual represented himself inadequately.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." Further, the 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...
Clause "does not mandate different standards of competency at various stages of or for different decisions made during the criminal proceedings."
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."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".
Further, in a decision, McKaskle v. Wiggins
McKaskle v. Wiggins
McKaskle v. Wiggins, 465 U.S. 168 , is a United States Supreme Court case in which the court considered the role of standby counsel in a criminal trial where the defendant conducted his own defense...
, 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.
Implications for evaluation
Following this decision, a forensic clinician conducting 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....
for competency to stand trial, should also include an evaluation of competency to waive counsel.
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 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....
- List of criminal competencies