Cooper v. Oklahoma
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OR:

''Cooper v. Oklahoma'', 517 U.S. 348 (1996), was a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case in which the Court reversed an
Oklahoma Oklahoma (; Choctaw language, Choctaw: ; chr, ᎣᎧᎳᎰᎹ, ''Okalahoma'' ) is a U.S. state, state in the South Central United States, South Central region of the United States, bordered by Texas on the south and west, Kansas on the nor ...
court decision holding that a
defendant In court proceedings, a defendant is a person or object who is the party either accused of committing a crime in criminal prosecution or against whom some type of civil relief is being sought in a civil case. Terminology varies from one jurisdic ...
is presumed to be competent to stand trial unless he proves otherwise by the second highest legal
standard of proof In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...
, that of
clear and convincing evidence In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...
, ruling that to be
unconstitutional Constitutionality is said to be the condition of acting in accordance with an applicable constitution; "Webster On Line" the status of a law, a procedure, or an act's accordance with the laws or set forth in the applicable constitution. When l ...
.. The court said the defendant's Fourteenth Amendment rights to
due process Due process of law is application by state of all legal rules and principles pertaining to the case so all legal rights that are owed to the person are respected. Due process balances the power of law of the land and protects the individual pers ...
were violated. In this case, the defendant's ability to understand the
charge Charge or charged may refer to: Arts, entertainment, and media Films * ''Charge, Zero Emissions/Maximum Speed'', a 2011 documentary Music * ''Charge'' (David Ford album) * ''Charge'' (Machel Montano album) * ''Charge!!'', an album by The Aqua ...
s against him and his ability to assist in his own
defense Defense or defence may refer to: Tactical, martial, and political acts or groups * Defense (military), forces primarily intended for warfare * Civil defense, the organizing of civilians to deal with emergencies or enemy attacks * Defense industr ...
was challenged on five separate occasions before and during his
trial In law, a trial is a coming together of Party (law), parties to a :wikt:dispute, dispute, to present information (in the form of evidence (law), evidence) in a tribunal, a formal setting with the authority to Adjudication, adjudicate claims or d ...
and
sentencing In law, a sentence is the punishment for a crime ordered by a trial court after conviction in a criminal procedure, normally at the conclusion of a trial. A sentence may consist of imprisonment, a fine, or other sanctions. Sentences for mult ...
for
capital murder Capital murder was a statutory offence of aggravated murder in Great Britain, and Northern Ireland, and the Republic of Ireland, which was later adopted as a legal provision to define certain forms of aggravated murder in the United States. In som ...
, but the trial judge ruled he was competent to stand trial because he did not meet Oklahoma's high standard of proof.


Circumstances

Byron Keith Cooper was charged in 1989 with the
murder Murder is the unlawful killing of another human without justification (jurisprudence), justification or valid excuse (legal), excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person wit ...
of an 86-year-old man while in the course of committing
burglary Burglary, also called breaking and entering and sometimes housebreaking, is the act of entering a building or other areas without permission, with the intention of committing a criminal offence. Usually that offence is theft, robbery or murder ...
. Both before and during his trial, the question of his competency to stand trial was raised five times. The first time the question arose, the trial judge relied on the opinion of a state
psychologist A psychologist is a professional who practices psychology and studies mental states, perceptual, cognitive, emotional, and social processes and behavior. Their work often involves the experimentation, observation, and interpretation of how indi ...
in determining to commit the defendant to a state
psychiatric hospital Psychiatric hospitals, also known as mental health hospitals, behavioral health hospitals, are hospitals or wards specializing in the treatment of severe mental disorders, such as schizophrenia, bipolar disorder, eating disorders, dissociative ...
for three months of treatment. Upon Cooper's return, the trial judge heard
testimony In law and in religion, testimony is a solemn attestation as to the truth of a matter. Etymology The words "testimony" and "testify" both derive from the Latin word ''testis'', referring to the notion of a disinterested third-party witness. La ...
from two state psychologists regarding Cooper's competence, but as these
experts An expert is somebody who has a broad and deep understanding and competence in terms of knowledge, skill and experience through practice and education in a particular field. Informally, an expert is someone widely recognized as a reliable s ...
disagreed over whether Cooper was competent to stand trial, the judge decided to rule against Cooper and ordered the trial to proceed. After the pretrial hearing was completed, the
defense attorney A criminal defense lawyer is a lawyer (mostly barristers) specializing in the defense of individuals and companies charged with criminal activity. Some criminal defense lawyers are privately retained, while others are employed by the various ...
raised the issue of Cooper's competence a third time, telling the court that Cooper's behavior was "odd" and that he refused to communicate with his attorney. The attorney said that it could be a serious matter "if he's not faking". However, the judge declined to review his earlier decision that Cooper was competent to proceed. On the first day of trial, Cooper's bizarre behavior (such as fleeing from his defense attorney, refusing to change his
prison A prison, also known as a jail, gaol (dated, standard English, Australian, and historically in Canada), penitentiary (American English and Canadian English), detention center (or detention centre outside the US), correction center, correc ...
clothes because regular clothes "burned" him, and talking to himself while in the
fetal position Fetal position (British English: also foetal) is the positioning of the body of a prenatal fetus as it develops. In this position, the back is curved, the head is bowed, and the limbs are bent and drawn up to the torso. A compact position is ...
) induced the court to conduct a further competency hearing. This time the trial judge observed Cooper and heard testimony from people including lay
witness In law, a witness is someone who has knowledge about a matter, whether they have sensed it or are testifying on another witnesses' behalf. In law a witness is someone who, either voluntarily or under compulsion, provides testimonial evidence, e ...
es, defendant Cooper, and a third psychologist who concluded that Cooper was incompetent. While expressing his uncertainty and not disagreeing with the psychologist, the judge ruled against Cooper and ordered the trial to proceed, finally opining: The trial proceeded with Cooper continuing to act in a bizarre manner and refusing to be near his attorney. Cooper was
convicted In law, a conviction is the verdict reached by a court of law finding a defendant guilty of a crime. The opposite of a conviction is an acquittal (that is, "not guilty"). In Scotland, there can also be a verdict of "not proven", which is consid ...
of
first degree murder Murder is the unlawful killing of another human without justification or valid excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person without justification or excuse, especially the c ...
, and during the sentencing phase of the trial the history of Cooper's
childhood abuse Child abuse (also called child endangerment or child maltreatment) is physical, sexual, and/or psychological maltreatment or neglect of a child or children, especially by a parent or a caregiver. Child abuse may include any act or failure to ac ...
was recounted. Finally the defense attorney pleaded for either a
mistrial In law, a trial is a coming together of parties to a dispute, to present information (in the form of evidence) in a tribunal, a formal setting with the authority to adjudicate claims or disputes. One form of tribunal is a court. The tribunal, w ...
or further evaluation into Cooper's competence, describing Cooper's courtroom behavior: The court summarily denied the motion. Cooper received the
death penalty Capital punishment, also known as the death penalty, is the state-sanctioned practice of deliberately killing a person as a punishment for an actual or supposed crime, usually following an authorized, rule-governed process to conclude that t ...
after the jury recommended death. Cooper appealed, and the
Oklahoma Court of Criminal Appeals The Oklahoma Court of Criminal Appeals is one of the two highest judicial bodies in the U.S. state of Oklahoma and is part of the Oklahoma Court System, the judicial branch of the Oklahoma state government.
affirmed both the conviction and the sentence. Cooper appealed to the Supreme Court on a
writ In common law, a writ (Anglo-Saxon ''gewrit'', Latin ''breve'') is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court. Warrants, prerogative writs, subpoenas, a ...
of
certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
.


Decision

In a unanimous verdict, the Supreme Court reversed the judgment and remanded the case back to the Oklahoma Court of Criminal Appeals for further consideration in light of their opinion. The Court held that the State may not proceed with a criminal trial when the defendant has demonstrated that he is more likely than not to be incompetent. Requiring a higher standard of proof, that of "
clear and convincing evidence In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...
", was too high a
standard of proof In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts ...
for a defendant to demonstrate a need for a competency evaluation, increasing the possibility of error to a level "incompatible with the dictates of
due process Due process of law is application by state of all legal rules and principles pertaining to the case so all legal rights that are owed to the person are respected. Due process balances the power of law of the land and protects the individual pers ...
". Criminal defendants must be allowed to avoid trial if they prove incompetence by a "preponderance of the evidence." The court used the relevant history of
common law In law, common law (also known as judicial precedent, judge-made law, or case law) is the body of law created by judges and similar quasi-judicial tribunals by virtue of being stated in written opinions."The common law is not a brooding omnipresen ...
regarding competency and the treatment of the insane and also compared Oklahoma's standards with the contemporary practices of other states, finding that only 4 of the 50 states used Oklahoma's heightened standard of proof. They concluded that this "demonstrates that the vast majority of jurisdictions remain persuaded that the heightened standard of proof imposed on the accused in Oklahoma is not necessary to vindicate the State's interest in prompt and orderly disposition of criminal cases." The court found most states uses a burden of proof far lower, or imposed no burden of proof at all, once the competency question is raised.


Significance

The American Academy for Psychiatry and the Law unofficially considers this decision a
landmark case Landmark court decisions, in present-day common law legal systems, establish precedents that determine a significant new legal principle or concept, or otherwise substantially affect the interpretation of existing law. "Leading case" is commonly u ...
in competency to stand trial
case law Case law, also used interchangeably with common law, is law that is based on precedents, that is the judicial decisions from previous cases, rather than law based on constitutions, statutes, or regulations. Case law uses the detailed facts of a l ...
. The court stated that no one questions the
fundamental right Fundamental rights are a group of rights that have been recognized by a high degree of protection from encroachment. These rights are specifically identified in a constitution, or have been found under due process of law. The United Nations' Sustai ...
of competency to stand trial. As established in '' Dusky v. United States'', a defendant has a fundamental right not to be put to trial unless he has "sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding . . . nda
rational Rationality is the quality of being guided by or based on reasons. In this regard, a person acts rationally if they have a good reason for what they do or a belief is rational if it is based on strong evidence. This quality can apply to an abili ...
as well as
fact A fact is a datum about one or more aspects of a circumstance, which, if accepted as true and proven true, allows a logical conclusion to be reached on a true–false evaluation. Standard reference works are often used to check facts. Scient ...
ual understanding of the proceedings against him." A State may not proceed with a criminal trial after the defendant has demonstrated that he is more likely than not to be incompetent.


See also

*
List of United States Supreme Court cases, volume 517 This is a list of all the United States Supreme Court cases from volume 517 of the ''United States Reports The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...
*
List of United States Supreme Court cases This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States. By Chief Justice Court historians and other legal scholars consider each Chief J ...
*
Lists of United States Supreme Court cases by volume The following is a complete list of cases decided by the United States Supreme Court organized by volume of the ''United States Reports'' in which they appear. This is a list of volumes of ''U.S. Reports'', and the links point to the contents of e ...
*
List of United States Supreme Court cases by the Rehnquist Court This is a partial chronological list of cases decided by the United States Supreme Court during the Rehnquist Court, the tenure of Chief Justice William Rehnquist from September 26, 1986, through September 3, 2005. The cases are listed chronolo ...
*''
Drope v. Missouri ''Drope v. Missouri'', 420 U.S. 162 (1975), was a United States Supreme Court case in which the Court held a Missouri trial court deprived a defendant of due process by failing to order a competency examination after he was hospitalized followin ...
'' (1975) *''
Ford v. Wainwright ''Ford v. Wainwright'', 477 U.S. 399 (1986), was a Lists of United States Supreme Court cases, landmark Supreme Court of the United States, U.S. Supreme Court case that upheld the common law rule that the insane cannot be Capital punishment in the ...
'' (1986)


Footnotes


External links

*
Oklahoma Uniform Jury Instructions regarding competency decisions
{{Criminal due process, competence, state=expanded Mental health case law in the United States United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 1996 in United States case law United States Fourteenth Amendment case law