Law School Case Brief
Godinez v. Moran - 509 U.S. 389, 113 S. Ct. 2680 (1993)
A defendant who waives his right to the assistance of counsel need not be more competent than a defendant who does not because there is no reason to believe that the decision to waive counsel requires an appreciably higher level of mental functioning than the decision to waive other constitutional rights. Thus, while it is undeniable that in most criminal prosecutions defendants could better defend with counsel's guidance than by their own unskilled efforts, a criminal defendant's ability to represent himself has no bearing upon his competence to choose self-representation.
After defendant Moran pleaded not guilty to three counts of first-degree murder and two psychiatrists concluded that he was competent to stand trial, he informed the Nevada trial court that he wished to discharge his attorneys and change his pleas to guilty. The court found that Moran understood "the nature of the criminal charges against him" and was "able to assist in his defense", that he was "knowingly and intelligently" waiving his right to the assistance of counsel, and that his guilty pleas were "freely and voluntarily" given. He was ultimately sentenced to death. When Moran subsequently sought state postconviction relief, the trial court held an evidentiary hearing before rejecting his claim that he had been mentally incompetent to represent himself, and the State Supreme Court dismissed his appeal. A Federal District Court denied his petition for a writ of habeas corpus, but on appeal, the Court of Appeals reversed. It concluded that due process required the trial court to hold a hearing to evaluate and determine Moran's competency before it accepted his decisions to waive counsel and plead guilty. It also found that the postconviction hearing did not cure the error, holding that the trial court's ruling was premised on the wrong legal standard because competency to waive constitutional rights requires a higher level of mental functioning than that required to stand trial. The appellate court reasoned that, while a defendant is competent to stand trial if he has a rational and factual understanding of the proceedings and is capable of assisting his counsel, he is competent to waive counsel or plead guilty only if he has the capacity for reasoned choice among the available alternatives.
Should defendant's petition for a writ of habeas corpus should have been granted?
The Supreme Court reversed decision of the appellate court, holding that defendant had made a voluntary, knowing, and intelligent waiver of his right to counsel, and voluntarily entered his guilty plea. The Court held that a defendant who waived his right to the assistance of counsel was not required to be more competent than a defendant who did not,because there was no reason to believe that the decision to waive counsel required an appreciably higher level of mental functioning than the decision to waive other constitutional rights. As to the guilty plea, Moran's decision to plead guilty was no more complicated than the sum total of decisions that a defendant could have been called upon to make during the course of a trial.
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