Godinez v. Moran, 509 U.S. 389 (1993)

In Godinez v. Moran, the U.S. Supreme Court held that a criminal defendant who is competent to stand trial under Dusky v. United States, 362 U.S. 402 (1961), is also competent to enter a guilty plea and to waive the right to counsel. Thus, a defendant who has a basic understanding of the criminal process, his charges, and their consequences and who can recount pertinent facts to his attorney—the criteria for competency to stand trial—is also competent to waive his rights to trial by jury, remain silent, and confront accusers (the rights waived when one pleads guilty) and competent to decide to represent himself. The Court also held that a defendant who pleads guilty or waives counsel must do so ‘‘knowingly and voluntarily,’’ which requires that defendants actually understand the relevant facts (but does not necessarily require that the decision be ‘‘rational’’).

Applying this standard, the Court refused to overturn the death sentences of Moran, who was found competent to stand trial by the evaluating psychiatrists and the trial judge, but who clearly was extremely depressed when he fired his attorneys, pleaded guilty, and presented no evidence at his capital Sentencing proceeding. This case increases the risk that defendants who are irrational, but who can demonstrate a basic understanding of the criminal process, will be allowed to make important decisions and to represent themselves, to their obvious detriment.

CHRISTOPHER SLOBOGIN

References and Further Reading

• Slobogin, Christopher, and Amy Mashburn, The Criminal Defense Lawyer’s Fiduciary Duty to Clients with Mental Disability, Fordham Law Review 68 (2000): 1581–1642.

Cases and Statutes Cited

• Dusky v. United States, 362 U.S. 402 (1961)

See also Dusky v. U.S., 362 U.S. 402 (1960); Guilty but Mentally Ill; Guilty Plea; Insanity Defense; Right to Counsel