25 terms

Forensic Psych Juvenile Case Law

U.S. ex rel Edney vs. Smith
the court held that in criminal cases the state should have access to the experts the defendant has decided not to use, once the issue of mental state at the time of the offense is properly raised.(insanity is raised)
Fare v Michael C (1979)
The Supreme Court ruled that a totality of the circumstances test is adequate to determine a valid waiver of rights during an interrogation of a juvenile. The court must look to all circumstances surrounding the interrogation. Some factors to consider are the juvenile's age, education, experience, intelligence, background, and whether the juvenile understands the warnings given and the consequences of waiving those rights. In this case, the juvenile was 16 ½, was currently on probation, had a record of prior offenses, had spent time in a youth corrections camp, was of average intelligence, and there was no coercion used. Therefore, under the totality of the circumstances, the juvenile voluntarily waived his rights and the confession was admitted.
In re Gault
the Fifth Amendment applies in juvenile delinquency proceedings. Presumably, the same constitutional rules that govern adult evaluations should also apply to these proceedings. Juveniles had their own protected right to due process. It established a. A requirement of notice of charges b. A right to an attorney c. A right to cross-examine and confront witnesses d. A right to avoid self-incrimination
Daubert v. Merrell Dow Pharmaceuticals
"an inference or assertion..derived by the scientific method". Opinion must be based on: (1) the scientific method, (2) "testability" of the theoretical basis for the opinion and the error rate associated with the methods used, (3) peer review, (4) general acceptance.
Frye v. U.S- Florida Standard-
Florida Standard- admissibility of scientific evidence should be conditioned on its being "sufficiently established to have gained general acceptance in the particular field to which it belongs".
Miranda vs. Arizona
"privilege against self incrimination" connected with 5th and 6th amendment, 5th being more important. Relies on the Fifth Amendment's "privilege against self incrimination" as the ground for excluding confessions.
Ake v. Oklahoma
U.S Supreme Court ordered that indigent defendants must be provided psychiatric expertise at the point of sentencing in a capital case in which mental condition or dangerousness is at issue
Estelle v. Smith
defendant's Fifth Amendment rights against self-incrimination as well as the Sixth Amendment right to counsel, and is therefore inadmissible at sentencing.
ALI - American Law Institute (1962)
a. (NOT USED IN FL) b. Considers mental impairments that may have affected the defendant's ability to control his actions i. Focus on cognitive components of "Appreciation" & "Volition" 1. Appreciation - The ability to comprehend one's own situation 2. Volition - (Broader term/ Not part of M'Naghten) Capacity to have behaved in some other manner at the time of the offense-insanity
M'Naghten Standard
a. (Used in FL) b. At the time of the offense, as a result of a mental disease or defect, the defendant did not know the nature or quality of his act or did not know that the act was wrong i. History - Based on the case of Daniel M'Naghten out of England in 1843 ii. M'Naghten shot and killed the secretary of the Prime Minister Robert Peel (Peel was the intended target) iii. Result of the case - Found NGRI & queen Victoria was outraged, asking for clarification of insanity
Wilson v. U.S (1968).
the court held that amnesia in and of itself is not grounds for incompetency
Riggins v. Nevada
the due process clause (14th amendment) prohibits prosecuting officials from administering involuntary doses of antipsychotic medicines for purposes of rendering the accused competent for trial
Sell v. U.S.
the court ruled that an inmate could be legally medicated against his or her will if a trial court determined that a. The individual facts of the case suggest that important governmental interests are served by getting the defendant competent and proceeding to trial b. The forced medication is substantially likely to significantly further those state interests c. Any less intrusive interventions are unlikely to provide the same benefits d. The medication is also in the best medical interest of the defendant
Jackson v. Indiana (1972)
- individuals found incompetent to stand trial cannot be held indefinitely if there is no real chance of recovering competency; if competency cannot be expected within a reasonable period of time, then the defendant must be released or civilly committed; court did not define reasonable, therefore states typically allow from 1 to 5 years of treatment to restore competency
Godinez v. Moran (1993)
(added to Miranda Warnings) - competency to waive counsel; court noted it was the same as competency to stand trial
1. Dusky vs. U.S. (1960)
Mandatory standard of competency to stand trial (1) sufficient present ability to consult with an attorney with a reasonable degree of rational understanding (2) a rational as well as a factual understanding of the proceedings taken against him/her; two broad areas cognitive and interpersonal.
Drope v. Missouri
The supreme court has ruled that the trial court must order and inquiries into comp see if bonafide doubt exists as to the defendant competency. The court must take into account and weigh any factor suggested of mental illness.
Pate v. Robinson
A hearing regarding competency is necessary under the due process clause of the Constitution of the United States.
Brown v. Board of Education
Credibility to scientific research; Many scientists and advocates for juveniles considered the result a triumph for neuroscience in the court, likening it to Brown v. Board of Education of Topeka, the landmark 1954 ruling that ended racial segregation in public schools. Brown v. Board was believed to be heavily influenced by a sociological study of children judging dolls of different colours. This purportedly showed that segregation had a negative impact on black students' self-esteem.
Jenkins v. US
And diagnosis of mental disease and mental defect, including the cause of relationships between mental disease for fact and overt behavior is the principal tool of the psychologist and found in psychological tests.
Medina v California
Defendant assumed competent until something arises; Prosecution of a defendant who lacks competency to stand trial violates the due process clause.
Roper v. Simmons
8th amendment: when referring to juveniles That commit murder before the age of 18 against execution of juvenile and concerns regarding the culpability of minors when compared to adults
Tate v Florida
Juvenile Law Center filed an amicus brief on behalf of a 12-year-old boy indicted by a grand jury, convicted of the first-degree murder, and sentenced to life in prison. Juvenile Law Center argued that the state should have been required to rebut the common law presumption that a twelve-year-old lacks the capacity to commit crimes; the trial court erred in failing to address the boy's competence to stand trial; the Florida transfer scheme violates the Fourteenth Amendment to the U.S. Constitution; and a sentence of life without parole imposed on a twelve-year-old violates both the U.S. and Florida Constitutions.The Court of Appeals reversed and remanded, finding that the youth's due process rights were violated by trial court's failure to order competency evaluations. The court rejected defendant's other challenges.
Kent v. US
There may be grounds for concerns that the child brought before juvenile court gets the worst of both worlds that he gets needed the protection of accorded to adults nor the solicitous care and regenerative treatment postulated for children.
Breed v. Jones
Set a precedent that juveniles can not be tried and acquitted in juvenile court then tried again in "adult" criminal court. Basically, the constitutional protection from double jeopardy applies to juveniles as well as adults. it is simply too late in the day to that a juvenile at a proceeding whoseconclude that need to my house is not in jeopardy at a proceeding whose object is to determine whether he has committed acts that violate a criminal law and whose potential consequences include both the stigma inherent in such a determination and deprivation of liberty for many years