Supreme Court of the United States
Estelle, Corrections Director v. Smith
May 18, 1981451 U.S. 454
Summary
The Court held that the State violated the defendant's Fifth and Sixth Amendment rights by using statements from a court-ordered competency examination to prove future dangerousness at the capital-sentencing phase without adequate warnings or an opportunity to consult counsel. The Court vacated the death sentence while leaving the murder conviction undisturbed and affirmed the lower appellate judgment. The opinion contains no separate opinions on record.
Holding
- Fifth Amendment privilege against compelled self-incrimination. When a defendant who has not placed psychiatric evidence at issue is subjected while in custody to a court-ordered psychiatric examination, the State may not use the defendant's statements from that examination to establish future dangerousness at a capital-sentencing proceeding unless the defendant was advised of the right to remain silent and the possible use of the statements and knowingly waived those rights. The competency examination could proceed if its results were limited to competency, but the statements could not be used for the State's sentencing case.
- Sixth Amendment right to counsel. After indictment and appointment of counsel, a psychiatric examination concerning a defendant's future dangerousness is a critical stage of the criminal proceedings. The defendant therefore must have a prior opportunity to consult with counsel about whether to participate and the purposes for which the examination may be used; no valid waiver was shown here. The Constitution did not require counsel's physical presence during the examination.
Docket 79-1127
Cited authorities
- Rule 40
- 28 U.S.C. § 2254
- 18 U.S.C. § 4244
- 83 Harv. L. Rev. 648
Cited by
- Commonwealth of Pennsylvania, Appellee v. James T. Williams, Appellant
- Sean Richard Sellers, Appellant v. State of Oklahoma, Appellee
- The People of the State of Illinois, Appellee v. John E. Whitehead, Appellant
- Quintin Phillippe Jones, Appellant v. the State of Texas
- The People of the State of Illinois, Appellee v. Girvies L. Davis, Appellant
- The People of the State of Illinois, Appellee v. Reginald Mahaffey, Appellant
- The People of the State of Illinois, Appellee v. Enice Lyles, Jr., Appellant
- Steven Shelton, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee