11 December 2013

Law in Plain English: Kansas v. Cheever

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

Scott Cheever. Photo from HutchPost.
SCOTUSblogKansas v. Cheever

Argument: Oct 16 2013 (Aud.)

Background: Cheever was charged with murder in federal court for the death of a law enforcement officer. Cheever intended to claim that although he killed the sheriff, he was intoxicated (by methamphetamine). As a result, the judge ordered a mental examination. The federal charges were later dismissed and reinstated in Kansas state court, where Cheever raised the same intoxication claim and presented an expert witness on his behalf. In response, prosecutors called the doctor who had examined Cheever in the federal case as a witness to testify that Cheever was not impaired at the time of the crime. Cheever was convicted and sentenced to death. The Kansas Supreme Court reversed the conviction, ruling that the admission of the doctor's testimony violated Cheever’s Fifth Amendment right against self-incrimination.

Issue: The question before the Court was whether, when a criminal defendant who affirmatively introduces expert testimony that he lacked the requisite mental state to commit capital murder of a law enforcement officer due to the alleged temporary and long-term effects of the defendant’s methamphetamine use, the state violates the defendant’s Fifth Amendment privilege against self-incrimination by rebutting the defendant’s mental state defense with evidence from a court-ordered mental evaluation of the defendant.

Holding: In an unanimous decision, the Supreme Court ruled that where a defense expert who has examined the defendant testifies that the defendant lacked the requisite mental state to commit a crime, the prosecution may offer evidence from a court-ordered psychological examination for the limited purpose of rebutting the defendant’s evidence. As a result, the court-ordered mental examination and the doctor's testimony was admissible. The Court distinguished Estelle v. Smith, in which the Court had previously held that the state may not force a defendant to submit to a psychiatric examination solely for the purposes of sentencing, with Buchanan v. Kentucky. In Buchanan, the Court ruled that if the defendant had raised a psychiatric defense and joined in the motion for a mental evaluation, the Fifth Amendment was not offended if the prosecution used the examination results to rebut the defense's claims. The practical impact of this decision is that prosecutors will continue to be able to use the defendant's mental evaluation as rebuttal evidence when the defense raises issues concerning the defendant's requisite mental state as an element of the crime.
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