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Golden v. State - 341 Ark. 656, 21 S.W.3d 801 (2000)

Rule:

While proceedings in a juvenile court need not conform with all the requirements of a criminal trial, primarily because of the special nature of the proceedings, essential requirements of due process and fair treatment must be met. A juvenile has a right to constitutionally adequate notice, the right against self-incrimination, and the right to cross-examine witnesses; further, a juvenile must be afforded the right to counsel during these proceedings. Logically, this right to counsel means little if the juvenile is unaware of the proceedings or unable to communicate with counsel due to a psychological or developmental disability. Therefore, a juvenile must be allowed to assert incompetency and have his competency determined prior to adjudication.

Facts:

On March 24, 1998, appellant Andrew Golden and another juvenile opened fire on their classmates at an elementary school in Jonesboro, Arkansas. One teacher and four students were killed, and one teacher and nine students were wounded. At the time of the shootings, Golden was 11 years old. The day after the shooting, a petition was filed, charging both boys with five counts of capital murder and ten counts of first-degree battery. At the probable cause hearing held on that same day, Golden's attorney informed the court that he intended to raise the affirmative defense of insanity and would also be raising issues concerning Golden's competency to proceed to trial. A separate hearing on these issues was later held at which the attorney argued that if the court denied Golden the right to argue lack of competency and insanity, it would violate Golden's constitutional rights of due process and equal protection. The trial court rejected those arguments, finding that based upon the nature of juvenile proceedings, Golden was not entitled to raise the issue of whether he was competent to stand trial or to assert the insanity defense. The trial judge reasoned that the safeguards present in juvenile proceedings allow the trial court to consider any alleged mental disease or defect during the disposition phase, when it was determining the appropriate placement for the juvenile. Following the issuance of the trial court's order, Golden's attorney informed the court that he wished to proceed to the adjudication hearing in order to preserve his right to argue the competency and insanity issues on appeal. An adjudication hearing was subsequently held in which the trial court adjudicated Golden guilty and sentenced him to an indeterminate period of time in the Division of Youth Services Training School. The court also provided that if Golden was released before the age of 21 years, he would remain in a juvenile detention center for up to 90 days. Challenging the trial court's decision, Golden asserted that the court violated his due process and equal protection rights by refusing to determine his competency, or fitness to proceed. Furthermore, Golden posited that the trial court violated his due process and equal protection rights by refusing to allow him to present an insanity defense.

Issue:

Did the trial court violate Golden's due process and equal protection rights: (i) by refusing to determine his competency, or fitness to proceed; or (ii) by refusing to allow him to present an insanity defense?

Answer:

(i) Yes; (ii) No.

Conclusion:

According to the Supreme Court of Arkansas, the law was clear that defendants in criminal cases had a fundamental right not to stand trial while incompetent. The court ruled that the such right protected criminal defendants' fundamental interests in their own liberty by ensuring that they were able to participate in their defense in an effort to avoid conviction and incarceration. Moreover, applying the doctrine enunciated in In re Gault, 387 U.S. 1, 18 L. Ed. 2d 527, 87 S. Ct. 1428 (1967), the court concluded that a juvenile must be allowed to assert incompetency and have his competency determined prior to adjudication. However, on the issue of raising the insanity defense, the court held that neither due process nor equal protection afforded defendant the right to an insanity defense where not provided for by statute or case law. According to the court, given the nature of juvenile proceedings and the rehabilitative rather than punitive purpose of such proceedings, a rational basis existed for affording adult criminal defendants in circuit court the right to assert the defense of insanity while not affording the same right to juveniles.

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