LOCATION: Denver Area Consortium
DOCKET NO.: 95-5207
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Oklahoma Court of Criminal Appeals
CITATION: 517 US 348 (1996)
ARGUED: Jan 17, 1996
DECIDED: Apr 16, 1996
Robert Alan Ravitz - Argued the cause for the petitioner
W. A. Edmondson - Argued the cause for the respondent
Facts of the case
Byron Keith Cooper was charged with the murder of an 86-year-old man in the course of a burglary. After an Oklahoma jury found him guilty of first-degree murder and recommended punishment by death, the trial court imposed the death penalty. Cooper's competence was considered on five separate occasions, whether he had the ability to understand the charges against him and to assist defense counsel. Oklahoma law presumes that a criminal defendant is competent to stand trial unless he proves his incompetence by clear and convincing evidence. Despite Cooper's bizarre behavior and conflicting expert testimony, he was found competent on separate occasions before and during his trial. In affirming the conviction and sentence, the Oklahoma Court of Criminal Appeals rejected Cooper's 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 under the Fourteenth Amendment.
May state law presume that defendants are competent to stand trial unless they prove their incompetence by clear and convincing evidence without violating the Due Process Clause of the Fourteenth Amendment?
Media for Cooper v. OklahomaAudio Transcription for Oral Argument - January 17, 1996 in Cooper v. Oklahoma
Audio Transcription for Opinion Announcement - April 16, 1996 in Cooper v. Oklahoma
William H. Rehnquist:
The opinion of the Court in No. 95-5207, Cooper against Oklahoma will be announced by Justice Stevens.
John Paul Stevens:
This case comes to us on a writ of certiorari to the Supreme Court of Oklahoma.
Petitioner Cooper was convicted in that State of first-degree murder.
His bizarre behavior and refusal or inability to communicate with counsel put petitioner’s competence to stand trial at issue both before and during the trial.
It is well settled that due process prohibits the trial of an incompetent defendant.
In previous cases, we have defined competence to stand trial as the present ability to understand the charges against you and to assist your attorney in making defense to those charges.
Under Oklahoma law, a criminal defendant who claims to be incompetence to stand trial or whose attorney makes this claim on his behalf is required to demonstrate incompetence by clear and convincing evidence.
Clear and convincing evidence is a heightened standard of proof which falls somewhere between preponderance of the evidence which is the normal civil standard and beyond the reasonable doubt the standard for criminal conviction.
The question presented by this case is whether application of Oklahoma’s heightened evidence rule violated petitioner’s federal constitutional right to due process by infringing on his fundamental rights to be tried only while competent.
The Okalahoma State Court rejected petitioner’s due process claim.
The State Supreme Court ruled that the risk of criminal defendant’s feigning incompetence combined with the State’s interest in the efficient functioning of its judicial process justify the clear and convincing standards.
In an opinion filed with Clerk today, we reverse.
We conclude that Oklahoma’s clear and convincing evidence rule has no substantial roots in prior practice.
At common law courts typically required a criminal defendant to prove his incompetence by a preponderance of the evidence.
Even today only three States in addition to Oklahoma plays a burden as high as clear and convincing evidence on the defendant.
The remaining 46 States as well as the Federal Government pose a lesser burden.
Moreover we find that the rule is fundamentally unfair in practice.
Oklahoma’s clear and convincing evidence test allows the State to precede the trial, even when the defendant has demonstrated that it is more likely than not that he is incompetent.
The consequences of preceding the trial while incompetent are serious for the defendant.
Other constitutional rights such as the right to a jury trial and the right to testify in one’s own defense can only be adequately exercised by a competent person.
We find that Oklahoma’s interest in the efficient operation of his criminal justice system is insufficient to overcome the defendant’s fundamental right not to be tried while incompetent.
The decision of the Court is unanimous.