Godinez v. Moran (Supreme Court, 1993): The Supreme Court determined the competency standard for a defendant to plead guilty or waive the right to counsel does not have to be higher or different from the Dusky Standard for Competency to Stand Trial. The Court held the decision to plead guilty is no more complicated than the sum total of decisions a defendant would make during the course of a trial (Whether to testify, waive a jury trial, or cross-examining witnesses for the prosecution). The decision to waive counsel did not require appreciably higher levels of mental functioning than the decision to waive other constitutional rights. The Court held the standard did not need to be higher as it had no bearing upon the defendant’s competency to CHOOSE to represent himself. The Court’s decision is a reflection of the competency to WAIVE right to counsel, no the ability to represent oneself. The Court also determined opining competence was not all that was necessary before the defendant could enter a plea of guilty or waive right to counsel. The Trial Court must determine the waiver is knowing, intelligent, and voluntary. This case superseded Seiling v. Eyman which set the former standard for Competency to Plead Guilty as the “Reasoned choice” standard.
Forensic & Psychological Assessments