''Godinez v. Moran'', 509 U.S. 389 (1993), was a

landmark decision Landmark court decisions, in present-day common law legal systems, establish precedents that determine a significant new legal principle or concept, or otherwise substantially affect the interpretation of existing law. "Leading case" is commonly ...

in which the

U.S. Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...

ruled that if a defendant was competent to stand trial, they were automatically competent to plead guilty, and thereby waive the panoply of trial rights, including the right to counsel..

Circumstances

On August 2, 1984, Richard Allen Moran entered the Red Pearl Saloon in

Las Vegas, Nevada Las Vegas, colloquially referred to as Vegas, is the most populous city in the U.S. state of Nevada and the county seat of Clark County. The Las Vegas Valley metropolitan area is the largest within the greater Mojave Desert, and second-l ...

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 Capital punishment, also known as the death penalty and formerly called judicial homicide, is the state-sanctioned killing of a person as punishment for actual or supposed misconduct. The sentence ordering that an offender be punished in s ...

. 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 Death is the end of life; the irreversible cessation of all biological functions that sustain a living organism. Death eventually and inevitably occurs in all organisms. The remains of a former organism normally begin to decompose sh ...

. 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 In common law jurisdictions, a preliminary hearing, preliminary examination, preliminary inquiry, evidentiary hearing or probable cause hearing is a proceeding, after a criminal complaint has been filed by the prosecutor, to determine whether the ...

and then it rejected his claim.

Appeals

Moran's appeal to the Nevada Supreme Court was dismissed and a

Federal District Court The United States district courts are the trial courts of the U.S. federal judiciary. There is one district court for each federal judicial district. Each district covers one U.S. state or a portion of a state. There is at least one feder ...

denied his petition for a

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. Warrant (legal), Warrants, prerogative writs, subpoenas, and ''certiorari'' are commo ...

habeas corpus ''Habeas corpus'' (; from Medieval Latin, ) is a legal procedure invoking the jurisdiction of a court to review the unlawful detention or imprisonment of an individual, and request the individual's custodian (usually a prison official) to ...

. However, the Court of Appeals reversed this decision, concluding that

due process Due process of law is application by the state of all legal rules and principles pertaining to a case so all legal rights that are owed to a person are respected. Due process balances the power of law of the land and protects the individual p ...

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 A constitutional right can be a prerogative or a duty, a power or a restraint of power, recognized and established by a sovereign state or union of states. Constitutional rights may be expressly stipulated in a national constitution, or they may ...

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 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 called supplication. In the colloquial sense, a petition is a document addressed to an officia ...

ed the Supreme Court on a

certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of a prerogative writ in England, issued by a superior court to direct that the recor ...

Decision

In a split decision (7–2), the Court found that competency to stand trial and competency to plead guilty were equivalent competencies. Therefore, 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 ''Pro se'' legal representation ( or ) means to argue on one's own behalf in a legal proceeding, as a defendant or plaintiff in civil cases, or a defendant in criminal cases, rather than have representation from counsel or an attorney. The ...

. The court held that it was irrelevant if the individual represented himself inadequately. (The Court later held in '' Indiana v. Edwards'' that the competency to stand trial was different from the competency to have self-representation.) 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 must make during the course of those proceedings."''Godinez'', 509 U.S. at 407 (Kennedy, J., concurring). Further, the

Due Process Clause A Due Process Clause is found in both the Fifth and Fourteenth Amendments to the United States Constitution, which prohibit the deprivation of "life, liberty, or property" by the federal and state governments, respectively, without due proces ...

"does not mandate different standards of competency at various stages of or for different decisions made during the criminal proceedings."

Implications for evaluation

Following this decision, a forensic clinician conducting a competency evaluation for competency to stand trial, should also include an evaluation of competency to waive counsel.

Subsequent developments

Moran was executed by

lethal injection Lethal injection is the practice of injecting one or more drugs into a person (typically a barbiturate, paralytic, and potassium) for the express purpose of causing death. The main application for this procedure is capital punishment, but t ...

on March 30, 1996. He remains the only person to be executed involuntarily in Nevada since the reinstatement of capital punishment.

Footnotes

External links

*
Competency to Stand Trial
{{Criminal due process, competence, state=expanded United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 1993 in United States case law Adjudicative competence case law