LANDMARK CASES IN FORENSIC PSYCHIATRY:
Defendants’ Rights
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Confessions
Guilty Pleas
Sex Offenders
Colorado v. Connelly, 1986
Case Summary:
While experiencing active psychosis, Connelly approached police and confessed to a murder. He was advised of his Miranda rights, provided a written statement, and there was no police coercion.
Connelly claimed violation of the 5th Amendment (self incrimination), arguing his confession was not voluntary as psychosis influenced his confession and his ability to make “free and rational” decisions..
US Supreme Court ruled that as there was no police coercion, which is the relevant standard for voluntariness, Connelly’s confession was voluntary despite the presence of psychosis.
Key Concepts:
For a confession to be found involuntary, there must be evidence of police coercion. Psychosis does not negate voluntariness.
North Carolina v. Alford, 1970
Case Summary:
Alford was facing first-degree murder charges. He maintained his innocence, but plead guilty to a lesser charge (second-degree murder) after considering the state’s evidence and potential sentences if convicted of the original charge.
The issue was raised as to whether Alford’s guilty plea was valid in consideration of the 6th Amendment Right to a Fair Trial and 14th Amendment Due Process Clause.
US Supreme Court ruled that pleading guilty while maintaining innocence is permissible as long as the plea is made intelligently, knowingly and voluntarily, with full understanding of the consequences.
Key Concepts:
It isn’t unconstitutional for a judge to accept a guilty plea from a defendant who maintains their innocence, however the plea must be intelligent, knowing and voluntary to be valid.
“Alford Plea”: pleading guilty while maintaining innocence, often as part of a plea bargain
Specht v. Patterson, 1967
Case Summary:
Specht was convicted of a sexual offense carrying a max sentence of 10 years, but. without notice or hearing, he was sentenced to an indeterminate term (up to life) under the CO Sex Offenders Act. He was thus convicted under one law, and sentenced under another.
The CO Sex Offenders Act required a psychiatric evaluation and written report, but no judicial hearing.
Specht filed habeas corpus, arguing violation of the 14th Amendment Due Process Clause.
US Supreme Court ruled that as the CO Sex Offenders Act used the original criminal conviction to initiate a new criminal proceeding to determine if criteria for treatment as a sex offender were met, the new criminal proceeding was subject to due process protections.
Key Concepts:
Due Process requires criminal procedural safeguards for sexual offender commitment proceedings, including rights to a judicial hearing, to counsel, to present evidence & witnesses, to confront & cross-examine witnesses.
Allen v. Illinois, 1986
Case Summary:
Allen was convicted of a sexual offense. The state sought civil commitment under the Illinois Sexually Dangerous Persons Act (SDPA) on the basis of mental illness and propensity to commit sexual offenses.
Allen argued the SPDA was unconstitutional as it involved mandatory psychiatric evaluations which he claimed violated 5th Amendment protection from self-incrimination.
US Supreme Court ruled that commitment under the SDPA was civil, not criminal, thus 5th Amendment protections didn’t apply. The purpose of the commitment is treatment, not punishment.
Key Concepts:
Civil commitment of sexual offenders is a civil, not criminal, proceeding, thus 5th Amendment protections from self-incrimination don’t apply.
Kansas v. Hendricks, 1997
Case Summary:
As Hendricks, a convicted sex offender, neared the end of his sentence, the state pursued civil commitment under the Sexually Violent Predator Act (SVPA).
Hendricks argued double jeopardy & ex post facto, and challenged the constitutionality of the SVPA as it allowed for commitment on the basis of a “mental abnormality” rather than a “mental illness” that predisposes to sex offenses.
US Supreme Court ruled that civil commitment statutes are not constitutionally required to use the term “mental illness”.
SVPA doesn’t constitute double jeopardy as the purpose of civil commitment is not punishment. The lack of effective treatments for sex offenders doesn’t make the commitment criminal.
Ex post facto doesn’t apply as no additional punishments were being imposed
Key Concepts:
Civil commitment of sex offenders doesn’t violate double jeopardy and ex post facto, as the purpose of commitment is not punishment.
Civil commitment statutes are not constitutionally required to use the term “mental illness.”
Kansas v. Crane, 2002
Case Summary:
Crane, a convicted sex offender, was civilly committed under the Sexually Violent Predator Act (SVPA) after completing his sentence.
Civil commitment under the SVPA required findings of both a mental illness and an inability to control one’s behavior. Crane did not meet the criteria of complete lack of control over dangerous behavior.
US Supreme Court found the SVPA didn’t require a complete inability to control one’s behavior, only “serious difficulty.”
Key Concepts:
Civil commitment of sex offenders under Kansas’ SVPA does not require complete inability to control one’s behavior, only “serious difficulty.”
McKune v. Lile, 2002
Case Summary:
Lile, a convicted sex offender, was required to participate in a Sexual Abuse Treatment Program (SATP). Non-participation would result in reduction of privileges and transfer to a max-security facility.
The SATP required completion of an “Admission of Responsibility” detailing one’s sexual history, including uncharged offenses. Lile refused, arguing 5th Amendment (self incrimination) concerns.
US Supreme Court found the SATP was not unconstitutional, as it:
Didn’t compel self-incrimination
Served legitimate penological interests (rehabilitation & public safety)
Penalties for non-participation weren’t punitive, atypical, or significant hardships
Key Concepts:
A Kansas SATP that required admission of past uncharged sexual offenses did not violate the 5th Amendment right to protection from self incrimination.
US v. Comstock, 2010
Case Summary:
Comstock, a convicted sex offender, was nearing the end of his sentence when civil commitment under the Adam Walsh Child Protection & Safety Act was pursued.
This act provided for civil commitment of sexually dangerous individuals in federal custody
Comstock argued Congress didn’t have the constitutional authority to enact the act.
US Supreme Court ruled that Congress has authority to enact the act under the “Necessary and Proper” Clause.
Key Concepts:
The federal government has the authority to enact civil commitment statutes for sexually dangerous individuals in federal custody under the “Necessary and Proper” clause.