holding that a person with a mental illness, including a history of hallucinations and delusions, may be capable of waiving her constitutional rights, unless the confession flows from an internal compulsion to confess that is rooted in a mental disease
How later courts described this case
- holding that a person with a mental illness, including a history of hallucinations and delusions, may be capable of waiving her constitutional rights, unless the confession flows from an internal compulsion to confess that is rooted in a mental disease
- stating that defendants with psychological problems are indeed able to make a valid waiver of their Miranda rights
- holding defendants with proven psychological defects are capable of waiving their constitutional rights and give voluntary confessions
- despite defendant's mental illness, the Court found that the waiver of rights was knowing, voluntary and intelligent where uncontested police testimony showed that defendant was read his Miranda rights, asked for clarification and stated he understood each warning, that he could read and write and denied recent drug use, and that he was not coerced into making confession
Written by the judges who cited it.
The opinion
McDERMOTT, Justice,
concurring.
I join in the opinion announcing the judgment of the Court, but write separately to express the following views.
There is no doubt that there are cases which upon their face are so bizarre, so alien to the ordinary, that they raise the question of whether a sane man would do them. However, the issue of when a person is sane as to be legally responsible is only part of the problem directly before us.
The first question is whether that issue can be fairly tried. That involves a determination of whether the person is competent to stand trial, so as to be able to assert and cooperate in a defense, whatever that defense may be. In determining that question a court cannot decide solely upon the conduct as alleged or conceded by the accused, i.e., that because the conduct itself outrages normal expectations the accused is incompetent to stand trial. There must be more than seeming bizarre methods; otherwise active criminal intent could be hidden simply by the method employed. Some evidence beyond the method employed must be presented, and one cannot avoid trial simply because they say they are insane or incompetent at the time of the crime.
A court may determine competency by observing the accused, ordering medical and psychiatric evaluation, or hearing the previous history and the present evaluation of medical experts offered by either side, none of which the court is required to accept or believe.
When the court has made a decision on competency we cannot differ with that finding because we would have found differently; nor are we in a position to evaluate the *638 accused or the witnesses who the court has accepted or rejected. Neither we, nor the court below, however, should determine competency solely because the methods employed are outrageous or bizarre. This of course cannot satisfy every differing view on what constitutes competency, but it is all we have on the preliminary question and its defects cut both ways.
The ultimate safeguard is that at trial fact finders are entitled to rule according to their own wisdom under all the facts. At trial the question is different; the issue there is whether the person is sane under the law, a consideration that includes the conduct itself as well as any other evidence offered. Hearing all, factfinders may choose to believe what they will, and decide that no sane person would do what was done, regardless of what any one says. They may also believe the accused was a sane person who chose bizarre or unusual methods to accomplish his own purposes. Unless there is more than the method employed by the accused they should hear the case and make the final decision.
LARSEN, J., joins in this opinion.