Edmond v. United States Case Brief

Facts of the Case

Petitioner inmates were each convicted by court-martial, which convictions and sentences were affirmed in whole or part by the Coast Guard Court of Criminal Appeals and then by the next reviewing court. Petitioners sought review, alleging that the appointments of civilian judges to the Coast Guard Court of Criminal Appeals by the Secretary of Transportation were invalid because the Secretary of Transportation and not the Judge Advocate General had appointed the civilian judges sitting on the panel that affirmed petitioners’ convictions.

Question

In capital cases, does the Fourteenth Amendment require the government to provide an indigent defendant with the psychiatric assistance necessary to prepare an effective insanity defense?

CONCLUSION

“Yes and yes. In an opinion delivered by Justice Antonin Scalia, the Court held that the judicial appointments were valid. The Court unanimously found that Congress has authorized the Secretary to appoint civilian members of the Coast Guard Court of Criminal Appeals. Accordingly, the Court also reasoned that the Secretary’s 1993 appointments of the two civilian judges in question were valid under the Appointments Clause, since such judges were inferior officers within the clause’s meaning, by reason of the supervision of the judges’ work by the General Counsel and by the Court of Appeals for the Armed Forces. Justice Scalia noted that the Appointments Clause gives the President the exclusive power to select principal officers by and with the advice and consent of the Senate, but authorizes Congress to “vest the Appointment of…inferior Officers…in the Heads of Departments.” Justice David H. Souter filed an opinion concurring in part and concurring in the judgment.”

Case Information

Citation: 520 US 651 (1997)
Argued: Feb 24, 1997
Decided: May 19, 1997
Case Brief: 1997