Ake v. Oklahoma

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Ake v. Oklahoma

Argued November 7, 1984
Decided February 26, 1985


Full case name:	Glen Burton Ake v. Oklahoma

Citations:	470 U.S. 68; 105 S. Ct. 1087; 84 L. Ed. 2d 53; 1985 U.S. LEXIS 52; 53 U.S.L.W. 4179

Prior history:	On appeal from the Court of Criminal Appeals of Oklahoma

Holding

An indigent criminal defendant in a murder case where the death penalty could be assessed had a right to have the state provide a psychiatric evaluation to be used in the defendant's behalf.

Court membership

Chief Justice: Warren E. Burger
Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor

Case opinions

Majority by: Marshall
Joined by: Brennan, White, Blackmun, Powell, Stevens, O'Connor
Concurrence by: Burger
Dissent by: Rehnquist

Laws applied

U.S. Const.

Ake v. Oklahoma, 470 U.S. 68 (1985)^[1], was a case in which the Supreme Court of the United States held that an indigent criminal defendant in a murder case where the death penalty could be assessed had a right to have the state provide a psychiatric evaluation to be used in the defendant's behalf.

[edit] Facts

Glen Burton Ake was arrested and charged with murdering a couple and wounding their two children in 1979. At his arraignment, his bizarre behavior prompted the judge to order a psychiatric evaluation. This resulted in a report by the examining psychiatrist that Ake was delusional, and specifically that Ake "claims to be the 'sword of vengeance' of the Lord and that he will sit at the left hand of God in heaven." Ake was diagnosed as a probable paranoid schizophrenic, and a prolonged psychiatric evaluation was recommended to determine whether Ake was competent to stand trial.

Ake was then confined to a state hospital for several months, before he came to trial. Ake's attorney requested that the court appoint a psychiatrist to perform an evaluation specifically for the purpose of helping to adequately prepare and present an insanity defense. The court denied the request, holding that Ake had no right to such assistance. Ake was then tried and convicted of two counts of murder, and sentenced to death.

[edit] Opinion of the Court

The Court, in an opinion by Justice Marshall, framed the question as one of "[m]eaningful access to justice", weighing the individual interest in the accuracy of a criminal proceeding against the burden imposed on the state, in light of "the probable value of the psychiatric assistance sought, and the risk of error in the proceeding if such assistance is not offered".

The Court found that although both the individual and the state had a strong interest, but that "the State's interest in prevailing at trial - unlike that of a private litigant - is necessarily tempered by its interest in the fair and accurate adjudication of criminal cases." Requiring the state to make one psychiatrist available to indigent defendants was not an excessive financial burden, and the state could not assert the desire to press a strategic advantage at trial.

Chief Justice Burger wrote a brief concurring opinion, stressing only that the finding in this case was limited to the facts of this case.