Ake v. Oklahoma
Encyclopedia
Ake v. Oklahoma, 470 U.S. 68 (1985), was a case
in which the Supreme Court of the United States
held that an indigent criminal defendant had a right to have the state provide a psychiatric evaluation to be used in the defendant's behalf if he needed it.
, his bizarre behavior prompted the judge
to order a psychiatric competency evaluation
. This resulted in a report by the examining psychiatrist that Ake was delusional, and specifically that Ake "claims to be the 'sword of vengeance' of the Lord and that he will sit at the left hand of God in heaven." Ake was diagnosed as a probable paranoid schizophrenic, and a prolonged psychiatric evaluation was recommended to determine whether Ake was competent
to stand trial.
Ake was then confined to a state hospital for several months, before he came to trial. Ake's attorney
requested that the court appoint a psychiatrist to perform an evaluation specifically for the purpose of helping to adequately prepare and present an insanity defense. The court denied the request, holding that Ake had no right to such assistance. Ake was then tried and convicted of two counts of murder, and sentenced to death.
, framed the question as one of "[m]eaningful access to justice", weighing the individual interest in the accuracy of a criminal proceeding against the burden imposed on the state, in light of "the probable value of the psychiatric assistance sought, and the risk of error in the proceeding if such assistance is not offered".
The Court found that both the individual and the state had a strong interest, but that "the State's interest in prevailing at trial - unlike that of a private litigant - is necessarily tempered by its interest in the fair and accurate adjudication of criminal cases." Requiring the state to make one psychiatrist available to indigent defendants was not an excessive financial burden, and the state could not assert the desire to press a strategic advantage at trial.
Chief Justice
Burger
wrote a brief concurring opinion, writing for himself that "Nothing in the Court's opinion reaches noncapital cases." Before the opinions were finalized, Burger had asked Marshall to limit his opinion to capital cases, but failed.
Case law
In law, case law is the set of reported judicial decisions of selected appellate courts and other courts of first instance which make new interpretations of the law and, therefore, can be cited as precedents in a process known as stare decisis...
in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that an indigent criminal defendant had a right to have the state provide a psychiatric evaluation to be used in the defendant's behalf if he needed it.
Facts
Glen Burton Ake was arrested and charged with murdering a couple and wounding their two children in 1979. At his arraignmentArraignment
Arraignment is a formal reading of a criminal complaint in the presence of the defendant to inform the defendant of the charges against him or her. In response to arraignment, the accused is expected to enter a plea...
, his bizarre behavior prompted the judge
Judge
A judge is a person who presides over court proceedings, either alone or as part of a panel of judges. The powers, functions, method of appointment, discipline, and training of judges vary widely across different jurisdictions. The judge is supposed to conduct the trial impartially and in an open...
to order a psychiatric competency evaluation
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
. This resulted in a report by the examining psychiatrist that Ake was delusional, and specifically that Ake "claims to be the 'sword of vengeance' of the Lord and that he will sit at the left hand of God in heaven." Ake was diagnosed as a probable paranoid schizophrenic, and a prolonged psychiatric evaluation was recommended to determine whether Ake was competent
Competence (law)
In American law, competence concerns the mental capacity of an individual to participate in legal proceedings. Defendants that do not possess sufficient "competence" are usually excluded from criminal prosecution, while witnesses found not to possess requisite competence cannot testify...
to stand trial.
Ake was then confined to a state hospital for several months, before he came to trial. Ake's attorney
Lawyer
A lawyer, according to Black's Law Dictionary, is "a person learned in the law; as an attorney, counsel or solicitor; a person who is practicing law." Law is the system of rules of conduct established by the sovereign government of a society to correct wrongs, maintain the stability of political...
requested that the court appoint a psychiatrist to perform an evaluation specifically for the purpose of helping to adequately prepare and present an insanity defense. The court denied the request, holding that Ake had no right to such assistance. Ake was then tried and convicted of two counts of murder, and sentenced to death.
Opinion of the Court
The Court, in an opinion by Justice MarshallThurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
, framed the question as one of "[m]eaningful access to justice", weighing the individual interest in the accuracy of a criminal proceeding against the burden imposed on the state, in light of "the probable value of the psychiatric assistance sought, and the risk of error in the proceeding if such assistance is not offered".
The Court found that both the individual and the state had a strong interest, but that "the State's interest in prevailing at trial - unlike that of a private litigant - is necessarily tempered by its interest in the fair and accurate adjudication of criminal cases." Requiring the state to make one psychiatrist available to indigent defendants was not an excessive financial burden, and the state could not assert the desire to press a strategic advantage at trial.
Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Burger
Warren E. Burger
Warren Earl Burger was the 15th Chief Justice of the United States from 1969 to 1986. Although Burger had conservative leanings, the U.S...
wrote a brief concurring opinion, writing for himself that "Nothing in the Court's opinion reaches noncapital cases." Before the opinions were finalized, Burger had asked Marshall to limit his opinion to capital cases, but failed.