Godinez, Warden v. Moran
Decided on June 24, 1993; 509 US 389


Murder case focuses attention on the mental competency standard

I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed: Criminal Justice (procedure), 14th Amendment

B. Legal Question Presented:

Is the competency standard for pleading guilty or waiving the right to counsel higher than the competency standard for standing trial?

II. CASE SUMMARY:

A. Background:

Respondent Moran pleaded not guilty to three counts of first-degree murder. Two psychiatrists concluded that he was competent to stand trial. He discharged his attorneys and changed his pleas to guilty. He was ultimately sentenced to death. Moran subsequently sought state post conviction relief, claiming that he was mentally incompetent to represent himself. The trial court held an evidentiary hearing before rejecting his claim. State Supreme Court dismissed his appeal and he filed a writ of habeas corpus.

A Federal District Court denied his petition for a writ of habeas corpus, but the Court of Appeals reversed. It concluded that due process required the trial court to hold a hearing to evaluate and determine Moran's competency before it accepted his decisions to waive counsel and plead guilty. It also found that the postconviction hearing did not cure the error, holding that the trial court's ruling was premised on the wrong legal standard because competency to waive constitutional rights requires a higher level of mental functioning than that required to stand trial. The court reasoned that, while a defendant is competent to stand trial if he has a rational and factual understanding of the proceedings and is capable of assisting his counsel, he is competent to waive counsel or plead guilty only if he has the capacity for reasoned choice among the available alternatives.

The US Supreme Court granted certiorari to review the case.

B. Counsel of Record:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Cal J. Potter III, by appointment of the Court, argued the cause for respondent. With him on the brief was Edward M. Chikofsky. David F. Sarnowski, Chief Deputy Attorney General of Nevada, argued the cause for petitioner. With him on the brief were Frankie Sue Del Papa, Attorney General, and Brooke A. Nielsen, Assistant Attorney General.
C. The Arguments:
ACLU Side
 
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
The American Civil Liberties Union et al. filed as amicus urging affirmance by Steven R. Shapiro, Diann Y. Rust-Tierney, John A. Powell, and Bruce J. Winick;

Additional amicus briefs urging affirmance were filed for the American Psychiatric Association et al. by James W. Ellis and Barbara E. Bergman; and the National Association of Criminal Defense Lawyers by Jon May.
The Criminal Justice Legal Foundation filed as amicus urging reversal by Kent S. Scheidegger and Charles L. Hobson


IV. THE SUPREME COURT'S DECISION:

"The competency standard for pleading guilty or waiving the right to counsel is the same as the competency standard for standing trial... There is no reason for the competency standard for either of those decisions to be higher than that for standing trial... Nor does the decision to waive counsel require an appreciably higher level of mental functioning than the decision to waive other constitutional rights. A higher standard is not necessary in order to ensure that a defendant is competent to represent himself, because the ability to do so has no bearing upon his competence to choose self-representation...

[W]hen a defendant seeks to waive his right to counsel, a determination that he is competent to stand trial is not enough; the waiver must also be intelligent and voluntary before it can be accepted. While States are free to adopt competency standards... the Due Process Clause does not impose them.

Reversed: The judgment of the Court of Appeals is reversed."
Justice Vote: 2 Pro vs. 7 Con

  • Thomas, C.  Con  (Wrote majority opinion)
  • Rehnquist, W.  Con  (Joined majority opinion)
  • White, B.  Con  (Joined majority opinion)
  • O’Connor, S.  Con  (Joined majority opinion)
  • Souter, D.  Con  (Joined majority opinion)
  • Kennedy, A.  Con  (Wrote concurring opinion)
  • Scalia, A.  Con (Joined Kennedy’s concurring opinion)
  • Blackmun, H.  Pro  (Wrote dissenting opinion)
  • Stevens, J.  Pro (Joined Blackmun’s dissent)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU filed as amicus urging affirmance; the US Supreme Court reversed the ruling in a 7-2 vote, giving the ACLU an apparent loss.