Godinez v. Moran
DECISION: Accused’s competency standard for pleading guilty or waiving right to counsel held not to be higher than rational-understanding competency standard for standing trial.
SUMMARY: A man who allegedly shot and killed three persons and attempted to kill himself pleaded not guilty in a Nevada state court to three counts of first-degree murder. The court ordered that the accused be examined by two psychiatrists, both of whom concluded that the accused was competent to stand trial. Two and a half months after the evaluations, the accused informed the court that he wished to discharge his attorneys and change his pleas to guilty. The court accepted the waiver of counsel and the guilty pleas after (1) finding, on the basis of the previous psychiatric reports, that the accused (a) understood the nature of the charges against him, (b) was able to assist in his defense, (c) knew the consequences of entering a guilty plea, and (d) was able to waive the right of counsel knowingly and intelligently; and (2) determining, on questioning the accused, that he (a) was knowingly and intelligently waiving his right to counsel, and (b) was freely and voluntarily pleading guilty. A sentencing panel of the court sentenced the accused to death for each of the murders, and the Supreme Court of Nevada affirmed with respect to two of the murders (103 Nev 138, 734 P2d 712). The accused, claiming that he had been mentally incompetent to represent himself, sought postconviction relief in state court. After an evidentiary hearing, the state court rejected the accused’s claim on the basis of the psychiatrists’ findings of competency. The Supreme Court of Nevada dismissed the accused’s appeal (105 Nev 1041, 810 P2d 335), and the United States Supreme Court denied certiorari (493 US 874, 107 L Ed 2d 160, 110 S Ct 207). The accused subsequently filed a habeas corpus petition in the United States District Court for the District of Nevada. The District Court denied the petition, but the United States Court of Appeals for the Ninth Circuit reversed and remanded on appeal, concluding that (1) there had been substantial evidence available when the accused pleaded guilty to trigger a good-faith doubt about his competency to waive constitutional rights; (2) due process thus required the trial court to have held a hearing to evaluate and determine the accused’s competency before accepting his decisions to waive counsel and plead guilty; (3) the correct legal standard of competency to waive counsel or plead guilty was whether the accused had the capacity for “reasoned choice” among the alternatives available to him; (4) the ruling in the postconviction hearing was wrongly based on the less stringent legal standard for competency to stand trial, that is, whether the accused had a rational and factual understanding of the proceedings and was capable of assisting counsel; and (5) the record did not support a finding that the accused was competent under the “reasoned choice” standard (972 F2d 263).
On certiorari, the Supreme Court reversed and remanded. In an opinion by Thomas, J., joined by Rehnquist, Ch. J., and White, O’Connor, and Souter, JJ., and joined in part (as to holding 4 below) by Scalia and Kennedy, JJ., it was held that (1) although the decision to plead guilty is a profound one, such a decision is no more complicated than the sum total of decisions that all criminal defendants, not merely those who plead guilty, may be called upon to make during the course of a trial; (2) if the rational-understanding standard is adequate for defendants who plead not guilty, that standard is necessarily adequate for those who plead guilty; (3) there is no reason to believe that the decision to waive counsel requires an appreciably higher level of mental functioning than the decision to waive other constitutional rights; and therefore (4) the standard for measuring a criminal defendant’s competency to plead guilty or waive the right to counsel is not higher than, or different from, the rational-understanding competency standard for standing trial.
Kennedy, J., joined by Scalia, J., concurring in part and concurring in the judgment, expressed the view that (1) the competency standard for pleading guilty and waiving the right to counsel is the same as the test of competency to stand trial, as such a single standard of competency (a) does not offend any principle of justice so rooted in the traditions and conscience of the people as to be ranked as fundamental, and (b) is not precluded by due process; and (2) the Supreme Court, in reaching its conclusion, should have avoided comparing the types of decisions made by one who goes to trial with the decisions required to plead guilty and waive the right to counsel.
Blackmun, J., joined by Stevens, J., dissenting, expressed the view that (1) a trial court should be required to conduct a specific inquiry into the question whether an accused who seeks to waive counsel can proceed alone and uncounselled, when the accused’s competency to stand trial already has been questioned; and (2) on the evidence in the case at hand, the trial judge should have conducted a separate competency evaluation to determine the accused’s capacity to waive counsel and represent himself, instead of relying on the psychiatrists’ reports that the accused was able to stand trial with the assistance of counsel.