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Law School Case Brief

Cooper v. Oklahoma - 517 U.S. 348, 116 S. Ct. 1373 (1996)

Rule:

A defendant may not be put to trial unless he has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and a rational as well as factual understanding of the proceedings against him.

Facts:

Oklahoma law presumed that a criminal defendant was competent to stand trial unless he proved his incompetence by clear and convincing evidence. Applying that standard, a judge found petitioner Cooper competent on separate occasions before and during his trial for first-degree murder, despite his bizarre behavior and conflicting expert testimony on the issue. In affirming his conviction and death sentence, the Oklahoma Court of Criminal Appeals rejected his argument that the State's presumption of competence, combined with its clear and convincing evidence standard, placed such an onerous burden on him as to violate due process.

Issue:

Did the Oklahoma law, in leaving the burden to prove competence by clear and convincing evidence with the accused, violate Cooper's Fourteenth Amendment rights?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States found that Cooper should not have had the higher burden of "clear and convincing evidence" placed on him, based on the historical reasons and procedures governing competency to stand trial. The Court found that the Fourteenth Amendment was violated unless the burden on Cooper was that of "preponderance of the evidence" because this represented the proper allocation of risk of error between Cooper and the prosecution.

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