Mental Health Issues and the Capacity to Stand Trial

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23/09/19 Law Reference this

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Position Paper

 The Supreme Court is the final judge in cases involving the highest law of all, being the Constitution. The Supreme Court is highly selective about which cases it chooses to consider, and only accepts cases that have been dealt with through the lower courts and appeals process. There have been numerous cases they have dealt with regarding mental health issues. These issues correspond with the Fourteenth Amendment and the right to “All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”(THE CLAUSES OF THE FOURTEENTH AMENDMENT) There have been several Supreme Court cases such as Ake v. Oklahoma, Clark v. Arizona, and Youngberg v. Romeo that has portrayed how mental illness crimes are examined.

 Glen Burton Ake broke into the home of Reverend Richard B. Douglass. He strangled him, his wife and their two children and pinned them to the floor. Clark shot Mr. and Mrs.Douglass and injured both kids. On the day of his trial Ake’s behavior was so bizarre that the judge ordered a psychiatric examination “for the purpose of advising with the Court as to his impressions of whether the Defendant may need an extended period of mental observation.” (United States Supreme Court AKE v. OKLAHOMA, (1985)). He was detected by an examiner psychiatrist who claimed that “[Ake] is a psychotic . . . his psychiatric diagnosis was that of paranoid schizophrenia – chronic, with exacerbation, that is with current upset, and that in addition . . . he is dangerous. . . . [B]ecause of the severity of his mental illness and because of the intensities of his rage, his poor control, his delusions, he requires a maximum security facility within – I believe – the State Psychiatric Hospital system.” (United States Supreme Court AKE v. OKLAHOMA, (1985)).

Ake was then committed to a mental hospital and after six months the chief forensic physiatrist informed the court that he was a mentally ill person in need of care and treatment, unable to stand trial. He was prescribed 200 milligrams of Thorazine, taken three times a day. Six weeks later, Ake was found to be adequate with his condition as long as he continued to be sedated with the antipsychotic drug. The state of Oklahoma then continued the proceedings and the defendant’s attorney informed the court that his client would be raising an insanity defense, which was his sole defense. Each of Clark’s examining psychiatrists testified, however they had no inquiry of his mental state during the time of the offense, or at his stay in the hospital. There was no solid testimony regarding Ake’s mental state at the time of the offense, which was a key factor in determining his sentence. His attorney requested a psychiatric evaluation to determine Ake’s mental state during the time of the crime, claiming he was entitled to the evaluation by the Federal Constitution.

The judge rejected the attorney’s argument and stated that the defendant requires the assistance of a psychiatrist when that assistance is necessary, and denied a psychiatric evaluation. The jury rejected the petitioner’s insanity defense and Ake was presumed sane during the time of the crime unless there was evidence to depict his sanity at the time. Ake was convicted on two counts of murder in the first degree, two counts of shooting with the intent to kill, and 500 years of imprisonment. The Oklahoma Court of Criminal Appeals confirmed the convictions and sentenced Ake to the death penalty on the murder counts due to the psychiatrists’ testimonies of the future dangers Ake could bear on society. Ake claimed he should have been provided with the services of a court-appointed psychiatrist and the court has the authority to review the case. The court rejected the argument and stated they could not provide these services to indigents charged with capital crimes.

Ake had no other errors in his other claims and the court granted an order to be reviewed by a higher court. The Supreme Court took on his case where Justice Thurgood Marshall declared that the Fourteenth Amendment requires the government to provide an indigent defendant with the psychiatric assistance necessary to implement an effective insanity defense. The Supreme Court reversed his conviction and Ake was sentenced to two life sentences for the tragic murders of Mr. and Mrs. Douglass. This case presents a side of the law that deals with diagnosing the mentally insane. Psychiatrists did not have enough credible sources to testify on behalf of Ake and their testimonies heavily impacted the outcome of a case.

Erick Clark was driving aimlessly playing loud music when police officer, Jeffrey Moritz, pulled Clark’s car over. When Moritz stopped the car, Clark shot and killed him. Initially, Clark was found incompetent to stand trial and was committed to a hospital for treatment. The trial proceeded two years later, and rather than Clark confessing to shooting and killing Mortiz, he attempted to prove that his paranoid schizophrenia at the time of the offense was to blame for the intent of shooting the officer. The prosecutor had circumstantial evidence which stated that Clark had previously mentioned he wanted to shoot police and came to the conclusion that Clark lured the victim by playing loud music at the scene to intentionally kill him.

Clark raised the insanity defense and rebutted the prosecution’s evidence by challenging the Arizona Supreme Court amendment that resulted from the decision of State v. Mott. By means of State v. Mott, the judge refused to rely on psychiatric testimony to refute mens rea in a crime, which is the intention or knowledge of wrongdoing in part of a crime. Arizona’s insanity law violated the petitioner’s right to due process under the United States Constitution’s Fourteenth Amendment on whether Arizona’s exclusion of evidence and refusal to consider mental disease or defect to rebut the state’s evidence on the element of mens rea. Clark presented another testimony describing his intense strange behavior over the year of the shooting. A psychiatrist testified that Clark was suffering from paranoid schizophrenia with delusions about “aliens” trying to kill him when he killed the officer. Expert testimonies claimed that the defendant was incapable of luring the officer or understanding right from wrong, therefore he was considered insane during the time of the crime.

 Several states, such as Arizona, use the M’Naghten test to determine whether a person accused of a crime was sane at the time of its occurrence. A psychiatrist from the state of Arizona claimed that Clark’s schizophrenia did not keep him from knowing the difference of right from wrong. The judge sentenced Clark to first degree murder, resulting from the capacity evidence of his actions before and after the shooting, corroborating no signs of his schizophrenia distorting his perception of reality, and “intentionally or knowingly killing a law enforcement officer who is in the line of duty.” (Metzner) Clark appealed this verdict, announcing that Arizona’s insanity test and the Mott rule violated due process, and the trial court’s refusal to apply his mental illness evidence to its determination of mens rea. The court denied his statement of the Arizona Legislature because due process prohibited Arizona from narrowing its insanity test or from excluding evidence of mental illness and incapacity due to mental illness to rebut evidence of the requisite criminal intent.

The Supreme Court affirmed the ruling of the Arizona Court of Appeals for failing to find a due process violation in Mott’s ban on considering mental illness evidence to negate the required criminal intent. The justices began dissecting the M’Naghten test by addressing the due process challenge. “The observational evidence included an expert witness’s account of “Clark’s tendency to think in a certain way and his behavioral characteristics” (Metzner). The mental disease evidence consisted of testimonies from professional psychologists or psychiatrists based on opinions from parts of their examinations stating that Clark suffered from a mental disease. The capacity evidence was claimed by the same expert psychologists and psychiatrists and concentrated on the specific details of the mental condition that makes the difference between sanity and insanity. Justice Kennedy opened his statement by saying the Court is incorrect for the holding Arizona has on Eric Clark. He was freed due to the incapacity to collect evidence regarding mens rea. This case disclosed the privilege Clark received based on his mental illness. There was no justice served for the police officer.

Nicholas Romeo had lived with his parents until his father died and his mother was no longer able to care for him. He has the mental capacity of an 18-month old, an I.Q. between 8 and 10. Romeo was admitted to the Pennhurst State School and Hospital two weeks after his father’s passing. Soon after it was noted that he was injured on 63 different occasions and was held in restraints on a routine basis for long periods of time. His mother filed a lawsuit against Pennhurst and claimed that her son had constitutional rights to “safe conditions of confinement, freedom from bodily restraint, and training or “habilitation” and that petitioners knew, or should have known, about his injuries but failed to take appropriate preventive procedures, thus violating his rights under the Eighth and Fourteenth Amendments.” (YOUNGBERG V. ROMEO)

The trial began and she explained that she was unable to care for Romeo or control his violence. He was examined by a physician and psychologist, and was certified to be severely retarded and unable to care for himself. The District Court advised the jury that if they deny Romeo the right to treatment his constitutional rights were breached under the Eighth Amendment, which defines there should be no cruel and unusual punishments inflicted. The jury issued their verdict in favor of Romeo. The Court of Appeals reversed and remanded for a new trial, holding that the Fourteenth Amendment’s due process guarantee provided the proper constitutional rights based on the right to treatment.

The Supreme Court began to question how Romeo involuntarily committed to a state institution for the mentally retarded, has rights under the Due Process Clause of the Fourteenth Amendment. They considered multiple sections of the amendment such as safe conditions of confinement, freedom from bodily restraints, and “habilitation.” The court asserted that “The mere fact that Romeo has been committed under proper procedures does not deprive him of all substantive liberty interests under the Fourteenth Amendment.” (Youngberg v. Romeo, 457 US 307 (1982)) The en banc court did not agree on the standard that Romeo’s rights had been violated because majority of the Court of Appeals concluded that the physical restraint can be justified only by “compelling necessity.”

The Supreme Court began to review and affirmed the constitutional due process liberty rights of involuntarily committed individuals with intellectual and developmental disabilities. Justice Lewis Powell began to question whether a respondent who has been involuntarily committed to state institution has rights under the due process clause of the Fourteenth Amendment. The defendant argued that he has “constitutionally protected liberty interest in safety, freedom of movement, and training within the institution; and that petitioners infringed these rights by failing to provide constitutionally required conditions of confinement.” (Alford) However, the court argued that Romeo has been committed under proper procedures therefore it does not deprive him of liberty interests under the Fourteenth Amendment. The State must provide the essentials such as adequate food, shelter, clothing, medical care and reasonable safety for all residents and personnel within the institution. Romeo retains liberty from safety and and freedom of bodily restraint, however it was undecided if it was adequate to habilitation. This case conveys the restrictions of liberty or restraints that may be necessary or appropriate to prove one’s case in a lawsuit similar to this, due to his mother admitting him to Pennhurst in the first place.

The Supreme Court reached their verdict in each case by basing their decision on the Constitution. In Ake v. Oklahoma the court overturned the verdict of the death penalty due to his paranoid schizophrenia and allowed him to be given a psychiatric evaluation in regards to the Fourteenth Amendment. In Clark v. Arizona, Erick Clark was freed due to insufficient evidence regarding mens rea. In Youngberg v. Romeo, the court was left undecided because he was habilitated in Pennhurst involuntarily. These decisions by the Supreme Court, whether agreed with or not show that individuals with mental health issues are entitled to having their capacity to stand trial judged fairly by the highest count of the law.

Works Cited

         “Clark v. Arizona 548 U.S. 735, 126 S. Ct. 2709 (2006)”, Law School Case Briefs for Class Prep, www.lexisnexis.com/lawschool/resources/p/casebrief-clark-v-arizona.aspx

         Cummings, Emily. “Clark v. Arizona: Summary & Decision”, study, study.com/academy/lesson/clark-v-arizona-summary-decision.html

  • “Glen Burton Ake”, Murderpedia, murderpedia.org/male.A/a/ake-glen-burton.htm
  • “Mentally ill man who murdered a Law Enforcement Officer may be released.”, Mental Illness Policy Org., mentalillnesspolicy.org/ngri/eric-clark-jeffrey-moritz.html
  • Metzner, Jeffrey. Wortzel, Hal. “Clark v. Arizona: Diminishing the Right of Mentally Ill Individuals to a Full and Fair Defense”, The Journal of the American Academy of Psychiatry and the Law, jaapl.org/content/34/4/545/tab-article-info#sec-1

         “United States Supreme Court AKE v. OKLAHOMA(1985) No. 83-5424”, Findlaw Ake v. Oklahoma, caselaw.findlaw.com/us-supreme-court/470/68.html

  • “United States Supreme Court CLARK v. ARIZONA(2006) No. 05-5966”, Findlaw Clark v. Arizona, caselaw.findlaw.com/us-supreme-court/548/735.html

       “United States Supreme Court YOUNGBERG v. ROMEO(1982) No. 80-1429”, Findlaw Youngberg v. Romeo, caselaw.findlaw.com/us-supreme-court/457/307.html

         “Youngberg v. Romeo”, American Psychological Association, www.apa.org/index.aspx

  • “Youngberg v. Romeo, 457 US 307 (1982)”, Disability Justice, disabilityjustice.org/youngberg-v-romeo-457-us-307-1982/
  • “Youngberg v. Romeo”, Oyez, www.oyez.org/cases/1981/80-1429

 

 

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