Cooper v. Oklahoma (1996)
Question: Does it violate the Due Process clause for states to presume competence unless it is proven by clear and convincing evidence?
Holding: Yes; the stringent standard is “incompatible with the dictates of due process,” and criminal defendants must be allowed to avoid trial if they prove incompetence by a “preponderance of the evidence.”
Drope v. Missouri (1975)
Question: Did the lower courts violate due process rights by proceeding with trial when the defendant was not present (due to his suicide attempt), and should his trial have been suspended until a competency determination was made?
Holding: The trial court failed to give proper weight to evidence of the petitioner’s incompetence. The correct course was to suspend trial until a competency determination could be made. There was insufficient inquiry to determine whether the petitioner’s right to be present should be waived, and remanding the case for psychiatric evaluation did not adequately protect due process rights; however, the state could retry the case IF the defendant was found competent.
Dusky v. US (1960)
Question: What is the proper and minimum standard to employ when establishing a defendant’s competency to stand trial?
Holding: A brief mental status examination is insufficient to establish competency to stand trial. “It is not enough for the district judge to find that ‘the defendant [is] oriented to time and place and [has] some recollection of events,’ but that the ‘test must be whether he has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding – and whether he has a rational as well as factual understanding of the proceedings against him.”
Estelle v. Smith (1981)
Question: When the accused does not introduce psychiatric evidence, may they be compelled to respond to questions posed by the evaluator since they could be used against him during sentencing?
Holding: No; the accused must be apprised of their rights and knowingly waive them.
Jackson v. Indiana (1972)
Question: What procedural safeguards must be observed for a defendant found incompetent to stand trial? How long may they be committed before it constitutes a violation of one’s due process rights?
Holding: Indefinite commitment for incompetence to proceed violates the Due Process Clause. At a minimum, the length of commitment must “bear some reasonable relation” to the reason for commitment. An incompetent defendant “cannot be held more than the reasonable period of time necessary to determine whether there is a substantial probability that he will attain that capacity in the foreseeable future.”
Medina v. California (1992)
Question: Should the burden of proof lie with the prosecution to demonstrate competency, or with the defense to prove incompetency to proceed?
Holding: A state statute presuming a defendant is competent to proceed and placing the burden of proof on the defendant to prove otherwise is “constitutionally adequate” to guard against due process violations.
Pate v. Robinson (1966)
Question: Was the appellant entitled to a hearing on competency? Was it a due process rights violation to not grant such a hearing?
Holding: The evidence raised a “bona fide doubt” about the defendant’s competency, and that is sufficient to conduct a hearing. The conviction of an incompetent person violates due process. Even in the absence of the defendant’s request for such a hearing, if there is sufficient evidence to raise the issue, it should be ordered by the judge.
Riggins v. Nevada (1992)
Question: Does forced administration of antipsychotic drugs during trial violate the Sixth and Fourteenth Amendments?
Holding: Yes; an individual has the right to freedom from an antipsychotic drug. In order to administer the drug over the individual’s objection, the state must establish a pressing need to do so. Justice Kennedy’s concurring opinion raised concerns about the drug altering one’s demeanor during trial.
Sell v. US (2003)
Question: Should (non-dangerous) criminal defendants be involuntarily medicated for the purpose of achieving competency to proceed?
Holding: To do so, the court must conclude the following: 1. Important government interests are at stake; 2. Involuntary medication will significantly further state interests, and the medication will likely render the defendant competent to proceed; 3. Less intrusive means are not likely to achieve the same results; 4. Administration of medication is medically appropriate.
US v. Duhon (2000)
Question: Does successful completion of a competency group for a person with an intellectual disability legitimately mean that he is competent to stand trial?
Holding: The hospital’s certification of competency failed to meet the minimal standards of reliability under Daubert, and the hospital’s finding of “competent to stand trial’ was rejected.
Wilson v. US (1968)
Question: Is it a denial of due process or the right to effective assistance of counsel to try a defendant with amnesia?
Holding: Amnesia is not a bar to competency per se. The Court should consider the following factors: 1) The extent to which amnesia affected the defendant’s capacity to assist; 2) The extent to which amnesia affected the defendant’s ability to testify; 3) The extent to which the evidence could be extrinsically reconstructed; 4) The extent to which the government assisted the defendant and counsel in that reconstruction; 5) The strength of the prosecution’s case. Most important here is whether the government’s case “is such as to negate all reasonable hypotheses of innocence;” 6) Any other facts and circumstances which would indicate whether or not the defendant had a fair trial.