United States Supreme Court cases involving mental health
Encyclopedia
The U.S. Supreme Court has issued numerous rulings regarding mental health and how society treats and regards the mentally ill. While some rulings applied very narrowly, perhaps to only one individual, other cases have had great influence over wide areas.
Year Case Ruling Right
ADA
1999 Albertsons Inc. v. Kirkingburg the Court held that not all individuals who suffer some sort of physical difficulty are per se "disabled" under the ADA. Instead, those who believe they suffer from a disability must prove their claim on a case-by-case basis by showing that their alleged disability substantially impacts on a major life activity ???

Year Case Ruling Right
CRIMINAL COMPETENCY
1960 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....

Affirming a criminal defendant's constitutional right to have a competency evaluation before proceeding to trial, and setting the standard for determination of such competence. BOR, 14th
1966 Pate v. Robinson A hearing regarding competency is necessary under the due process clause of the Constitution of the United States. BOR, 14th
1972 Jackson v. Indiana
Jackson v. Indiana
Jackson v. Indiana was a landmark decision of the U.S. Supreme Court that determined a state violated due process by involuntarily committing a criminal defendant for an indefinite period of time solely on the basis of his permanent incompetency to stand trial on the charges filed against...

Criminal defendants who have been found incompetent to stand trial are not permitted to be held indefinitely. There must be some possibility of becoming competent in a reasonable amount of time BOR, 14th
1975 Drope v. Missouri
Drope v. Missouri
Drope 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...

When deciding whether to evaluate a criminal defendant's competency, the court must considered any evidence suggestive of mental illness, even one factor alone in some circumstances. Therefore, the threshold for obtaining a competency evaluation is low. When the issue is raised, the motion should be granted. The defendant must not bear all the burden for raising the issue. BOR, 14th
1985 Ake v. Oklahoma
Ake v. Oklahoma
Ake v. Oklahoma, 470 U.S. 68 , was a case in which the Supreme Court of the United States held that an indigent criminal defendant had a right to have the state provide a psychiatric evaluation to be used in the defendant's behalf if he needed it....

Indigent criminal defendants have a right to a competency evaluation BOR, 14th
1996 Cooper v. Oklahoma
Cooper v. Oklahoma
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,...

the burden for proving incompetency is only preponderance; due process would be violated if the burden is required to be carried by clear and convincing evidence.

Year Case Ruling Right
DEATH PENALTY
1986 Ford v. Wainright Preventing the execution [capital punishment] of the insane, requiring an evaluation of competency and an evidentiary hearing] 1st
1993 Godinez v. Moran
Godinez v. Moran
Godinez v. Moran, 509 U.S. 389 , 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.-Circumstances:...

Competency to stand trial includes the abilities to plead guilty and to waive the right to counsel 1st
1976 Profitt v. Florida Permitted comparison of mitigating (including mental health reasons) and aggravating factors to decide death penalty decisions. See also Furman v. Georgia
Furman v. Georgia
Furman v. Georgia, was a United States Supreme Court decision that ruled on the requirement for a degree of consistency in the application of the death penalty. The case led to a de facto moratorium on capital punishment throughout the United States, which came to an end when Gregg v. Georgia was...

 (1972), and Gregg v. Georgia
Gregg v. Georgia
Gregg v. Georgia, Proffitt v. Florida, Jurek v. Texas, Woodson v. North Carolina, and Roberts v. Louisiana, 428 U.S. 153 , reaffirmed the United States Supreme Court's acceptance of the use of the death penalty in the United States, upholding, in particular, the death sentence imposed on Troy Leon...

 (1976))
1st
2005 Roper v. Simmon In a ruling that followed Wainright (in assessing the nature of cruel and unusual punishments), children may not be given the death penalty 1st
2010 Graham v. Florida
Graham v. Florida
Graham v. Florida was a decision by the Supreme Court of the United States, in 2010, in which it was held that juvenile offenders cannot be sentenced to life imprisonment without parole for non-homicide offenses. The court decided whether Roper v...

Likewise, children may not be given life sentences (without possibility of parole) for offenses that do not include murder 1st

Year Case Ruling Right
INSANITY
1978 Lockett v. Ohio
Lockett v. Ohio
Lockett v. Ohio, 438 U.S. 586 is a United States Supreme Court case in which the Court held that sentencing authorities must have the discretion to consider every possible mitigating factor, rather than being limited to a specific list of factors....

Sentencing authorities must have the discretion to consider every possible mitigating factor, rather than being limited to a specific list of factors. 1st

Year Case Ruling Right
TESTIMONY
1981 Estelle v. Smith
Estelle v. Smith
Estelle v. Smith, is a U.S. Supreme Court case in which the court held that, per Miranda v. Arizona , the state may not force a defendant to submit to a psychiatric examination solely for the purposes of sentencing...

The same doctor that evaluated the criminal defendant for competency also testified at the penalty phase of the trial. That violated the defendant's right against self incrimination. 5th, 6th

Year Case Ruling Right
ADDICTIONS
1962 Robinson v. California
Robinson v. California
Robinson v. California, 370 U.S. 660 , was a case in which the Supreme Court of the United States held that the use of civil imprisonment as punishment solely for the misdemeanor crime of addiction to a controlled substance was a violation of the Eighth Amendment's protection against cruel and...

Cannot make a person's status as an addict a crime; only behaviors can be criminal 1st
1968 Powell v. Texas
Powell v. Texas
Powell v. Texas, 392 U.S. 514 , was a United States Supreme Court case which ruled that a Texas statute criminalizing public intoxication did not violate the Eighth Amendment protection against cruel and unusual punishment. It was a 5-4 decision, and the majority opinion was by Justice Thurgood...

ditto for alcoholics
1984 Spaziano v. Florida
Spaziano v. Florida
Spaziano v. Florida, was two United States Supreme Court cases dealing with the imposition of the death penalty. In the first case, 454 U.S. 1037, , the Supreme Court, with two dissents, refused Spaziano's petition for certiorari...

It is constitutional for a judge to override a jury's recommendation of life imprisonment and impose the death penalty. Essentially overruled by Ring v. Arizona
Ring v. Arizona
Ring v. Arizona, , is a case in which the United States Supreme Court applied the rule of Apprendi v. New Jersey, , to capital sentencing schemes, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. Ring overruled a portion of...

.
1985 Glass v. Louisiana
Glass v. Louisiana
Glass v. Louisiana, , was a case decided by the United States Supreme Court in 1985.- Background :Jimmy L. Glass was sentenced to death by the state of Louisiana...

Electrocution does not violate Eight Amendment
1986 Ford v. Wainwright
Ford v. Wainwright
Ford 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...

Execution of insane persons banned under Eighth Amendment.

Year Case Ruling Right
RIGHT TO TREATMENT
1976 Estelle v. Gamble
Estelle v. Gamble
Estelle v. Gamble, , was a case decided by United States Supreme Court that held that in order to state a cognizable Section 1983 claim for a violation of Eighth Amendment rights, a prisoner must allege acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical...

Established that Prisoners are a minimum level of treatment, including mental health care 8th

Year Case Ruling Right
RIGHT TO REFUSE TREATMENT
1978 Rennie v. Klein
Rennie v. Klein
Rennie v. Klein was a case heard in the Federal District Court of New Jersey in 1978 to decide whether an involuntarily committed mental patient has a constitutional right to refuse psychiatric medication...

CIVIL-an involuntarily committed, legally competent patient who refused medication had a right to professional medical review of the treating psychiatrist's decision. The Court left the decision-making process to medical professionals. 14th
1990 Washington v. Harper
Washington v. Harper
Washington v. Harper 494 U.S. 210 is a case in which an incarcerated inmate sued the state of Washington over the issue of involuntary medication, specifically antipsychotic medication.-Circumstances:...

CRIMINAL-Prisoners have only a very limited right to refuse psychotropic medications in prison. The needs of the institution take precedence over the prisoners' rights. However, there must be a formal institutional hearing, the prisoner must be found to be dangerous to himself or others, the prisoner must be diagnosed with a serious mental illness, and the mental health care professional must state that the medication prescribed is in the prisoner's best interest. 14th
1992 Riggins v. Nevada
Riggins v. Nevada
Riggins v. Nevada, is a U.S. Supreme Court case in which the court decided whether a mentally ill person can be forced to take antipsychotic medication while they are on trial to allow the state to make sure they remain competent during the trial....

CRIMINAL-In a ruling very similar to Harper, the Court found that the State may force administration of psychotropic medications to a pre-trial detainee, if it establishes a medical need for the drug, and a need for the detainee's safety and that of others. To the Harper requirements, they added "less restrictive alternative" language, which requires the State to document that there are no behavioral, environmental, or other measures available that will be equally effective. 6th, 14th

Year Case Ruling Right
CIVIL COMMITMENT
1972 Jackson v. Indiana
Jackson v. Indiana
Jackson v. Indiana was a landmark decision of the U.S. Supreme Court that determined a state violated due process by involuntarily committing a criminal defendant for an indefinite period of time solely on the basis of his permanent incompetency to stand trial on the charges filed against...

due process requires that the nature and duration of commitment bear some reasonable relation to the purpose for which the individual is committed.” Reasoning that if commitment is for treatment and betterment of individuals, it must be accompanied by adequate treatment, several lower courts recognized a due process right 14th
1979 Addington v. Texas
Addington v. Texas
Addington v. Texas , , is a U.S. Supreme Court landmark case that set the standard for involuntary commitment for treatment by raising the burden of proof required to commit persons for psychiatric treatment from the usual civil burden of proof of "preponderance of the evidence" to "clear and...

Raised the burden of proof requirement, in order to civilly commit a person, from preponderance, to clear and convincing. Also, permitted the courts to defer judgment regarding a person's need for commitment, to the doctor(s) 14th
1979 Parham v. JR The Court ruled that minors may be civilly committed to mental health facilities without an adversary hearing; in essence, parents do have the right to commit their children. 14th
1982 Youngberg v. Romeo
Youngberg v. Romeo
Youngberg v. Romeo, 457 U.S. 307 , was a landmark United States Supreme Court case regarding the rights of the involuntarily committed and mentally retarded. Nicholas Romeo was mentally retarded with an infant level IQ and was committed to a Pennsylvania state hospital...

Each individual has a due process protected interest in freedom from confinement and personal restraint; an interest in reducing the degree of confinement continues even for those individuals who are properly committed. freedom from undue physical restraint and from unsafe conditions of confinement 14th
1974 Donaldson v. O'Connor In terms of impact, Connor v. Donaldson, may be the single most important decision in mental health law. It has been used by opponents of involuntary commitment to argue that civil commitment be limited to only mentally ill and dangerous persons. This interpretation has been important in hampering efforts to implement changes in commitment law (limiting access to treatment).

The Court stated, "A finding of 'mental illness' alone cannot justify a State's locking a person up against his will and keeping him indefinitely in simple custodial confinement… In short, a state cannot constitutionally confine without more a nondangerous individual who is capable of surviving safely in freedom by himself or with the help of willing and responsible family members or friends."
1993 Heller v. Doe Reflecting the more conservative ('pro-government') attitude of the times, the Court found that mentally retarded persons are not a 'suspect' class of persons (requiring the same level of protection as racial minorities); thus, governments are free to enact almost any legislation or rule to civilly commit them, and the courts will not intervene, short of illegal or ridiculous actions (called 'rational' scrutiny). 14th

Year Case Ruling Right
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1988 Lowenfield v. Phelps
Lowenfield v. Phelps
Lowenfield v. Phelps, 484 U.S. 231 is a United States Supreme Court case in which the Court held that the two jury polls and the supplemental charge did not impermissibly coerce the jury to return a death sentence, and that the death sentence does not violate the Eighth Amendment simply because...

Found that the function of restricting the class of murderers eligible for capital punishment can be accomplished by explicit law or by findings of aggravating circumstances
1988 Thompson v. Oklahoma
Thompson v. Oklahoma
Thompson v. Oklahoma, 487 U.S. 815 , was the first case since the moratorium on capital punishment was lifted in the United States in which the U.S. Supreme Court overturned the death sentence of a minor on grounds of "cruel and unusual punishment."...

Executions of offenders age fifteen and younger at the time of their crimes is unconstitutional under Eighth Amendment.
1989 Stanford v. Kentucky
Stanford v. Kentucky
Stanford v. Kentucky, , was a United States Supreme Court case that sanctioned the imposition of the death penalty on offenders who were at least 16 years of age at the time of the crime. This decision came one year after Thompson v...

Eighth Amendment does not prohibit the death penalty for crimes committed at age sixteen or seventeen. (Overturned in Roper v. Simmons (2005))
1989 Penry v. Lynaugh
Penry v. Lynaugh
Penry v. Lynaugh, , sanctioned the death penalty for mentally retarded offenders because the Court determined executing the mentally retarded was not "cruel and unusual punishment" under the Eighth Amendment...

Executing persons with mental retardation
Mental retardation
Mental retardation is a generalized disorder appearing before adulthood, characterized by significantly impaired cognitive functioning and deficits in two or more adaptive behaviors...

 is not a violation of the Eighth Amendment. (Overturned in Atkins v. Virginia (2002))
1990 Walton v. Arizona
Walton v. Arizona
Walton v. Arizona, 497 U.S. 639 , upheld two important aspects of the capital sentencing scheme in the U.S. state of Arizona — judicial sentencing and the aggravating factor "especially heinous, cruel, or depraved" — as not unconstitutionally vague. The Supreme Court has overruled the first of...

Found judicial sentencing and the aggravating factor "especially heinous, cruel, or depraved" are not unconstitutionally vague. (First finding overturned in Ring v. Arizona (2002))
1992 Morgan v. Illinois
Morgan v. Illinois
Morgan v. Illinois, 504 U.S. 719 , is a case decided by the United States Supreme Court.-Background:In an elaboration of the Witherspoon v. Illinois doctrine, the Rehnquist Court considered challenges to the selection of jurors who would automatically vote to impose the death penalty on a defendant...

A defendant may challenge for cause a prospective juror who would automatically vote to impose the death penalty in every capital case
1993 Herrera v. Collins
Herrera v. Collins
Herrera v. Collins, , is a case in which the Supreme Court of the United States ruled that a claim that the Eighth Amendment's ban on cruel and unusual punishment prohibits the execution of one who is actually innocent is not ground for federal habeas relief.-Background:On September 29, 1981,...

In the absence of other constitutional grounds, new evidence of innocence is no reason for federal court to order a new trial.
1995 Schlup v. Delo
Schlup v. Delo
Schlup v. Delo, 513 U.S. 298 , was a case in which the United States Supreme Court expanded the ability to reopen a case in light of new evidence of innocence.Petitioner Lloyd E...

Expanded the ability to reopen a case in light of new evidence of innocence
2002 Ring v. Arizona
Ring v. Arizona
Ring v. Arizona, , is a case in which the United States Supreme Court applied the rule of Apprendi v. New Jersey, , to capital sentencing schemes, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. Ring overruled a portion of...

A death sentence where the necessary aggravating factors are determined by a judge violates a defendant's constitutional right to a trial by jury.
2002 Atkins v. Virginia
Atkins v. Virginia
Atkins v. Virginia, , is a case in which the Supreme Court of the United States ruled 6-3 that executing the mentally retarded violates the Eighth Amendment's ban on cruel and unusual punishments.-The case:...

The execution of mentally retarded defendants violates the Eighth Amendment's ban on cruel and unusual punishment.
2004 Tennard v. Dretke
Tennard v. Dretke
Tennard v. Dretke, 542 U.S. 274 , was a United States Supreme Court case in which the court was asked whether evidence of the defendant's low IQ in a death penalty trial had been adequately presented to the jury for full consideration in the penalty phase of his trial...

Held that all relevant mitigating factors must be considered in the penalty phase of a death penalty case, not just in the trial phase
2004 Schriro v. Summerlin
Schriro v. Summerlin
Schriro v. Summerlin, 542 U.S. 348 , was a case in which the United States Supreme Court held that a requirement that a different Supreme Court decision requiring the jury rather than the judge to find aggravating factors would not be applied retroactively.-Facts:In April 1981, Warren Wesley...

Held that a requirement from the Ring decision requiring the jury rather than the judge to find aggravating factors would not be applied retroactively.
2005 Roper v. Simmons
Roper v. Simmons
Roper v. Simmons, was a decision in which the Supreme Court of the United States held that it is unconstitutional to impose capital punishment for crimes committed while under the age of 18. The 5-4 decision overruled the Court's prior ruling upholding such sentences on offenders above or at the...

The death penalty for those who had committed their crimes under 18 years of age is cruel and unusual punishment and violates the Eighth Amendment.
2006 Oregon v. Guzek
Oregon v. Guzek
Oregon v. Guzek, 546 U.S. 517 , was a decision by the Supreme Court of the United States, which ruled that the Eighth Amendment to the United States Constitution does not grant criminal defendants facing the death penalty the right to introduce new evidence of their innocence during sentencing that...

States may limit the evidence of innocence a defendant may present at his sentencing hearing to evidence already presented at his trial.
2006 Hill v. McDonough
Hill v. McDonough
Hill v. McDonough , was a case decided by the United States Supreme Court challenging the use of lethal injection as a form of execution in the state of Florida. The Court ruled unanimously that a challenge to the method of execution as violating the Eighth Amendment to the United States...

Allowed appeal on civil rights violation grounds, even after habeas appeal
2006 Kansas v. Marsh
Kansas v. Marsh
Kansas v. Marsh, 548 U.S. 163 , is a case decided by the United States Supreme Court. The Court held that a Kansas death penalty statute was consistent with the U.S...

States not prohibited from imposing the death penalty when mitigating and aggravating sentencing factors were both present.
2006 House v. Bell
House v. Bell
House v. Bell, 547 U.S. 518 , was a United States Supreme Court case challenging the permissibility of new DNA forensic evidence that becomes available post-conviction, in capital punishment appeals when those claims have defaulted pursuant to state law. The Court found that admitting new DNA...

Post-conviction DNA forensic evidence can be considered in death penalty appeals.
2008 Medellin v. Texas
Medellín v. Texas
Medellín v. Texas, 552 U.S. 491 is a United States Supreme Court decision which held that while an international treaty may constitute an international commitment, it is not binding domestic law unless Congress has enacted statutes implementing it or unless the treaty itself is "self-executing";...

A requirement imposed by a treaty is not binding unless it was enacted by a statute created by Congress.
2008 Baze v. Rees
Baze v. Rees
Baze v. Rees, 553 U.S. 35 , was a United States Supreme Court case. The court agreed to hear the appeal of two men, Ralph Baze and Thomas Bowling, who were sentenced to death in Kentucky. The men argue that executing them by lethal injection would violate the 8th Amendment prohibition of cruel and...

Found Kentucky's lethal injection method did not violate the Eighth Amendment
2008 Kennedy v. Louisiana
Kennedy v. Louisiana
Kennedy v. Louisiana, 554 U.S. 407 was a landmark decision by the Supreme Court of the United States that held that the Eighth Amendment's Cruel and Unusual Punishment Clause did not permit a state to punish the crime of rape of a child with the death penalty; more broadly, the power of the state...

States may not impose the death penalty for a crime "where the victim's life was not taken"
2009 Harbison v. Bell
Harbison v. Bell
Harbison v. Bell, 556 U.S. ___ was a decision by the Supreme Court of the United States that held that federal law gave indigent death row inmates the right to federally appointed counsel to represent them in post-conviction state clemency proceedings, when the state has declined to do so...

Indigent death row inmates sentenced under state law have a right to federally-funded habeas counsel in post-conviction state clemency proceedings, when the state has denied such counsel.

See also

  • Capital punishment in the United States
    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...

  • Participation of medical professionals in American executions
    Participation of medical professionals in American executions
    Participation of medical professionals in American executions is a controversial topic, due to its moral and legal implications. The practice is proscribed by the American Medical Association, as defined in its Code of Medical Ethics...

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