Colorado v. Connelly (1986)
Question: What constitutes a “voluntary, knowing, and intelligent” waiver of one’s Miranda rights? Should the state have to prove voluntary waiver of Miranda rights by “clear and convincing evidence?”
Holding: Coercive police activity is a necessary predicate to finding that a confession is not “voluntary” within the Due Process Clause of the Fourteenth Amendment. Statements made by the defendant after receiving Miranda rights could be admitted without violation of due process. The State only needs to be prove voluntary waiver of Miranda rights by a preponderance of the evidence.
Faretta v. California (1975)
Question: Under what circumstances can an individual, during State criminal court proceedings, waive the right to counsel in the interest of self-representation?
Holding: A defendant in a state criminal trial has a constitutional right to proceed without counsel when one voluntarily and intelligently elects to do so.
Godinez v. Moran (1993)
Question: Is the competency standard for pleading guilty or waiving the right to counsel higher than the competency standard for standing trial?
Holding: The standards for competency to plead and to waive the right to counsel are the same as the standard for competency to stand trial. The Dusky standard uniformly applies to all three areas of competency addressed in this case.
Indiana v. Edwards (2008)
Question: Does mental illness limit a defendant’s right to self-representation? Are Dusky criteria sufficient to establish a defendant’s competence to proceed pro se, or should the standard be higher?
Holding: A higher standard for competency to proceed pro se should be used, given the more complex abilities required to represent oneself in court as opposed to assist and consult with counsel. A court is permitted “to insist upon representation by counsel for those competent enough to stand trial under Dusky but who still suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.”
Miranda v. Arizona (1966)
Question: Is the government required to notify arrested defendants of their Fifth Amendment rights against self-incrimination before they interrogate them?
Holding: Yes; the government must notify arrested individuals of their Fifth Amendment constitutional rights, specifically: their right to remain silent, an explanation that anything they say could be used against them in court, their right to counsel, and their right to have counsel appointed to represent them if necessary. Without this notification, anything admitted by an arrestee in an interrogation will not be admissible in court.
North Carolina v. Alford (1970)
Question: Can a guilty plea be validly entered when the defendant maintains innocence of the crime? Is such a guilty plea in violation of the voluntariness requirement, or is pleading guilty to avoid the death penalty coercive?
Holding: “An individual accused of a crime may voluntarily, knowingly, and understandingly consent to the imposition of a prison sentence even if he is unwilling or unable to admit his participation in the acts constituting the crime.” A guilty plea may be accepted for a defendant who maintains his innocence, provided “the plea represents a voluntary and intelligent choice among the alternative courses of action open to the defendant.” A plea entered to avoid a negative outcome (e.g., the death penalty) “does not necessarily demonstrate that the plea of guilty was not the product of a free and rational choice, especially where the defendant was represented by competent counsel whose advice was that the plea would be to the defendant’s advantage.”