User:Tayb5192/Competency to Plead Guilty

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Competence to Plead Guilty

For a defendant to be competent to plead guilty they must have the present rational ability to assist and consult with their counsel, as well as maintain a rational and factual understanding of the proceedings against them. The plea of guilty must be intentional, voluntary, and the defendant must know and understand the consequences of the plea. This current standard for competence to plead guilty was established in the Godinez v. Moran (1993) case when the United States Supreme Court ruled that a person who is competent to stand trial is also competent to plead guilty. In doing so, they rejected the standard that as established in the 1973 Sieling v. Eyman case, which that ruled the level of competence for a defendant to plead guilty is higher than the level of competence needed for a defendant so stand trial.

(note from Tess - I suggest you add the heading and paragraph above into the Competence (law) page. Everything below this point probably does not belong on Wikipedia as it is written. You could integrate anything new and citable in the notes you have here about the Godinez v Moran case into the wiki page for that case, but there is no reason to duplicate the content of that page here. Re: the Sieling v Eyman case info - maybe there's a way to integrate a bit of that into the Godinez v Moran page? It was largely replaced by Godinez and so this might be why it's not prominently featured already in its own page. The other paragraphs below are written more in the style of a research paper than a wikipedia contribution, so arguably shouldn't be put up on wikipedia. I think this is a good example of what all you learned and know about this topic, but I woundn't suggest adding this all to wikipedia. I think the best way forward as you move this into the live wikipedia world is to post that paragraph and heading above to the Competence (law) page).

In Godinez v. Moran the defendant, Richard Moran, shot and killed three people and then attempted suicide. While recovering from his self-inflicted wounds at the hospital, he confessed to police that he had committed the three murders. Moran was evaluated by two separate psychiatrists for competency to stand trial. He was found to be both “knowledgeable” and had the ability to “assist his attorney in his own defense” . After being convicted on all three murders, Moran attempted to have this decision reversed on the basis that although he was found competent to stand trial, this didn't establish that he was competent to plead guilty. After the original ruling was reversed by the Ninth Circuit Court, the Supreme Court stated that in being found competent to stand trial by psychiatrists at the time that he plead guilty, the original convictions held, and Moran was sentenced to death. In doing so, the Supreme Court referenced Dusky v. United States on the basis that it establishes a defendant must have a ‘reasonable degree of understanding, and ability to consult with one's attorney, and a factual understanding of the proceedings being brought against him” . In addition to this, Justice Thomas also countered Moran’s appeal using Massey v. Moore and Gideon v. Wainwright, stating that neither of these cases established that a higher level of competency is needed to plead guilty, thus the Due Process Clause did not impose any additional requirements for a defendant to plead guilty. Supreme Court Justice Anthony Kennedy offered a concurring opinion with Justice Thomas in the Moran case, stating that requiring different levels of competency for various aspects of a trial would be "disruptive" to legal processes, and create "unworkable" conditions.

In result, the Supreme Court held that the Dusky standard was sufficient to determine if a defendant was both competent to stand trial and competent to plead guilty, and Moran’s original conviction held. The Supreme Court justified this decision by explaining that a person who is competent to stand trial is also competent to remain silent (or not), competent to decide whether they want to take the stand, and also competent for cross-examination, therefore, they’re component to waive their right to a jury trial and to plead guilty. Additionally, during the Moran case the court addressed the opinion that there should be differentiations between whether a defendant has the ability to understand the proceedings and whether they actually understand the significance and potential consequences from the decisions they are making. It was decided that a trial court is responsible for discerning whether the defendants capacity for comprehension and understanding depreciates during a trial. In addition to this, concerns were raised regarding a defendants ability to self-represent. The Supreme Court expressed that a defendants level of legal knowledge was "irrelevant" and has "no bearing on a defendants competence to make the decision to self-represent".

The history of competency to plead guilty reflects two different standards, a single-standard, where defendants who are found competent to stand trial are also believed to be competent to plead guilty, and a dual standard, where defendants must present a higher level of competency over and above being competent to stand trial in order to be found competent to plead guilty. The standard for competence to plead guilty was first established by the Ninth Circuit in the Sieling v. Eyman (1973) case. In Sieling v. Eyman, the defendant Gilbert Sieling was on trial for assault with a deadly weapon and multiple account of assault with the intent to commit murder. During his trial Mr.Sieling was examined by three separate psychiatrists to determine if he was competent to stand trial. After being found competent to stand trial by two of the three evaluators, Sieling’s case progressed past the hearing stage and while heading to trial Sieling requested to change his not-guilty plea to a plea of guilty in accordance with a plea-bargaining agreement. After being sentenced to 16 consecutive years in prison, Sieling petitioned the court that although he was competent to stand trial, he was incompetent to plead guilty. In a unanimous decision, the Ninth Circuit reversed based on the Arizona Supreme Court’s ruling in the Westbrook v. Arizona case which made a distinction between a defendant's competence to stand trial and a defendant's competence to waive the right to counsel and plead guilty. They justified this reversal, deciding that although Seiling was examined, his competence to make a “reasoned choice” was never established. This case set the standard that a person who pleads guilty has to understand the charges being brought against them, understand the consequences of the charges being brought against them, have the ability to intelligently understand the proceedings, and intelligently waive their constitutional rights. They stated that the degree of competence needed to submit a plea of guilty is higher than the level of competency needed for a defendant to waive their constitutional rights, establishing the dual-standard for competency to plead guilty.

In order for a guilty plea to be considered valid, it must be submitted “voluntarily and understandingly”, it must be “intentional” and the rights of the defendant must also be “known”. The due process clause of the Fourteenth amendment requires a defendant to be competent in order for a trial and conviction to take place. Additionally, the defendant must have a general “capacity” to make an intelligent choice- but what this “capacity” looks like has yet to be discerned by the courts. This concept has yet to be elaborated on, instead the courts tend to focus more on the circumstances surrounding a defendant submitting a guilty plea. Because entering a guilty plea includes the waiver of more than one constitutional right, most courts require a formal meeting with the defendant where multiple mental health experts are able to evaluate the defendant to ensure they meet the requirements listed above. It was established that if a person suffers from mental illness that substantially impairs one's ability to make a justified choice among all options presented, and their mental illness impedes the ability to understand the nature of the consequences that may ensure following a guilty plea, then they do not meet the criteria for competency to plead guilty.

The case Chapman v. Commonwealth (2007) is a real-life example of the competence to plead guilty standard being used in legal practice. This case involved a man, Marco Chapman, who broke into a woman's home and murdered her and two of her three children. During pretrial proceedings, Mr. Chapman was ordered to undergo a competency evaluation at the Kentucky Correctional Psychiatric Center (KCPC). Mr. Chapman was found competent to stand trial. Following this ruling, Mr.Chapman asked the court to dismiss his attorney, waive a jury trial and sentencing, he stated he plead guilty to all charges raised against him and asked to be sentenced to death. Following this letter to the court, Mr.Chapman was ordered to undergo a second competency evaluation. This evaluation led to a 30 day stay at KCPC for further treatment, and following the 30 days Mr.Chapman underwent a third and final competency evaluation. He was found competent and the court ruled he was competent to dismiss his attorneys, plead guilty, and seek the death penalty. Mr. Chapman was sentenced to death despite the Kentucky Department of Public Advocacy filing multiple appeals on his behalf. These appeals included claims that the death penalty is unconstitutional, Mr.Chapmans eighth amendment would be violated if he was subjected to lethal injection or the electric chair, and multiple other claims. The Kentucky Supreme Court, citing the Godinez v. Moran (1993) case ruled that Mr.Chapman was competent to plead guilty on the basis that he had the capacity to “appreciate the nature and consequences  of the proceedings against him”. This court ruling holds today, and the requirement for competent to plead guilty remains equal to the standard for a defendant to be competent to stand trial.

A recent study on competency to plead guilty (2018) used answers from real attorneys to get a better idea of how the issue of competence to plead guilty is raised in court. This study found that when juveniles are on trial and the issue of competence to plead guilty has been raised the three most common reasons are because of concerns regarding cognitive-intellectual abilities (19.5%(, concerns about defendant ability to adequately assist counsel (17.8%), and concerns about a defendants mental illness (14.4%). The attorneys from this study listed concerns about a defendants mental illness as the strongest predictor (39.5%) of them raising the issue of competence to plead guilty in cases where the defendant is an adult. When asked about reasons that as attorney's one may not raise the issue of competence to plead guilty, a majority of responses stated that the defendant did fall below the threshold for competence to plead guilty (47.3%), a threshold that many attorneys reported being '"too low".