Everything about Godinez V Moran totally explained
Godinez v. Moran,
Moran
petitioned the Supreme Court on a
writ of
certiorari.
Decision
In a split decision (7–2), the Court found that competency to stand trial and competency to plead guilty were equivalent competencies. In other words, 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. The court held that it was irrelevant if the individual represented himself inadequately.
As 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 [509U.S. 389, 407] must make during the course of those proceedings."
Significance
The court appears to be moving toward a single standard of competency to be applied throughout criminal proceedings. The court finds nothing in case law to the contrary. "[S]etting out varying competency standards for each decision and stage of a criminal proceeding would disrupt the orderly course of trial and, from the standpoint of all parties, prove unworkable both at trial and on appellate review."
Further, in a decision,
McKaskle v. Wiggins, the Court held that even if the defendant successfully waives counsel, the court can provide a "standby counsel" if the pro se defendant has actual control over the presentation of the case to the jury, and the jury retains the belief the defendant is in charge of his own case.
Implications for evaluation
Following this decision, a forensic clinican conducting a
competency evaluation for competency to stand trial, should also include an evaluation of competency to waive counsel.
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