Moran v. Godinez

In Moran v. Godinez (9th Cir. 1994) 57 F.3d 690, 697, a post-conviction competency hearing was held three years after the defendant's guilty plea. The defendant challenged the findings of the post-conviction court arguing that the court incorrectly placed the burden of proof on him to establish his incompetence. Citing to Medina v. California, supra, 505 U.S. 437, the Ninth Circuit held: "Thus, so long as the state provides adequate procedures to assess competence, it constitutionally may assign the burden of proof to the defendant." (Moran v. Godinez, supra, 57 F.3d at p. 697.) The Ninth Circuit further held that although the post-conviction court violated Nevada law by placing the burden on defendant, no deprivation of a substantive right occurred. The state had provided the defendant with constitutionally adequate procedures to evaluate his competency. (Moran v. Godinez, supra, 57 F.3d at pp. 697-698) In Moran v. Godinez, the defendant was in the hospital recovering from a suicide attempt when he summoned police and confessed to the murder of his wife and two other people. (Moran, supra, 57 F.3d at p. 694.) Three months later, the defendant appeared in a Nevada trial court, and "said he wanted to discharge his attorneys and plead guilty to prevent the presentation of mitigating evidence on his behalf." (Ibid.) Before accepting the waiver of counsel and guilty plea, the trial court interrogated the defendant. At one point, the court asked whether the defendant was under the influence of drugs or alcohol. The defendant responded that he was taking "just what they give me in, you know, medications." (Ibid.) The trial court did not ask any questions about that medication but simply moved on to other issues and then accepted the defendant's guilty plea. The Moran court found that the defendant's procedural due process rights were violated because a reasonable jurist should have entertained a good faith doubt about the defendant's competency at the change of plea hearing. (Moran, supra, 57 F.3d at p. 695.) The court reasoned that, at the time of that hearing, the trial judge knew that the defendant had attempted suicide three months earlier, and that he wanted to fire his attorneys, to plead guilty to three murders and to die. Furthermore, although the trial court declined to inquire about the nature of the defendant's medications, undisputed evidence in the record established that he was taking Inderal, Dilantin, Phenobarbital, and Vistaril at the time he entered is plea. The appellate record also contained evidence regarding the purpose and function of these medications. (Id. at p. 695.) The Moran court found that these circumstances established a reasonable doubt about the defendant's competence and should have led the trial court to conduct a competency hearing. The court also found, however, that a post-conviction retrospective competency hearing cured the error and established that the defendant was competent at the plea hearing. (Id. at p. 696.)