Ake v Oklahoma
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Ake v. Oklahoma
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Ake v. Oklahoma
A large percentage of defendants in crimes are impoverished. Psychiatric assessments are
costly and even more expensive when the individual being evaluated is in detention pending
trial. When Ake was arraigned in Court, his conduct was strange, and the judge ruled that Ake be
examined by a psychiatrist (Giannelli, 2003). Ake was determined to be fit to appear at trial six
weeks later, and trials continued. Ake's counsel notified the presiding judge that he would raise a
defense of sanity and asked for a psychiatric assessment at the expense of the State. The trial
court dismissed the request for such an examination, and the matter was appealed.
Ake v. Oklahoma Nature of Case
Meaningful access to justice; the right of criminal defendants to psychiatric assessments
in the death penalty and insanity defense Cases
Facts of the Case
Glen Burton Ake, the economically disadvantaged defendant, was deemed guilty of
murder with the intention to carry out homicide and first-degree manslaughter. His behaviour
was so strange at his initial Oklahoma hearing that the judge in attendance ordered him to be
assessed by a mental health expert immediately (Giannelli, 2003). Ake was found incapable
of facing trial by the assessing psychiatrist, who advised that he be committed. After six weeks in
a state mental institution, Ake was deemed competent of the requirement that he remained
sedated with antipsychotic medication.
The State subsequently restarted the judicial process, and during the initial hearing, Ake's
counsel notified the Court that he would pursue an insanity defense. The lawyer asked for a
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psychiatric assessment at the cost of the State to ascertain the plaintiff's psychological condition
when the crime was being committed (Giannelli, 2003). According to US ex rel, the lawyer
asserted that Ake had the right to such an examination under the Constitution. Smith v. Baldi, the
judicial proceedings denied Ake's petition for such an assessment (Groendyke, 2006).
Throughout the trial period of the ensuing trial, the assessing psychiatrists stated that Ake was
detrimental to the judicial process, although no evidence was available of Ake's psychological
condition at the precise moment of the crime.
The Court dismissed the insanity defense, and the defendant was deemed guilty on every
allegation. During the court hearing for the sentence, the State proceeded to seek the death
sentence on the murder charges, citing the assessing mental health expert's opinion as evidence
of Ake's future dangerous behavior. Ake received the death penalty since he lacked a specialist
testimony to rebut his claims or present evidence to mitigate his sentence (Giannelli, 2003). Ake
argued in his suit to the Appellate Oklahoma Court that Ake was eligible for the services of a
court-appointed mental health expert as an impoverished defendant. This argument was rejected
by the appeal Court, which confirmed Ake's convictions and incarceration, holding that he was
unable to be a court-appointed mental health professional.
Issue
Whether a financially disadvantaged defendant is protected under the Constitution to be
appointed at the State's cost by a psychologist to assist the defendant in preparing an insanity
defense and rebutting evidence regarding potential dangerousness.
Holding
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When a defendant's sanity has the potential to be brought into doubt during a criminal
judicial proceeding, the State is compelled by the Constitution, particularly the 14th Amendment,
to offer the assistance of a mental health professional. This Court holds that it undermines the
Constitution when a state utilizes its legal authority to pursue an indigent individual in a criminal
matter (Clair, 2021). The State should make all the necessary attempts to provide the defendant
with an impartial chance to represent themselves in a judicial proceeding. This fundamental
concept relies, in particular, on the 14
th
Amendment's fundamental equality, where due process
should be guaranteed.
The 14th Amendment forbids the State from actively denying someone an opportunity to
engage in their defense due to poverty. The Court defined the issue as rightful access to justice,
balancing a person's interest in the impartiality of a criminal proceeding against the State's
obligation (Pickett, 2023). An individual undergoing trial and the State have essential interests in
the process; however, the State's interest in achieving a conviction at trial must be balanced
against its duty to ensure the judicial process is impartial and that the criminal matter assessment
process is precise. Therefore, this requires the government to provide a psychiatrist or an expert
on the matter for the defendant should they fail or be unable to produce the same due to financial
reasons. At the hearing in Ake v. Oklahoma case, the State was unable to demonstrate any motive
to provide a mental health profession for Ake with a motive to obtain a strategic advantage in the
proceedings.
When a defendant's mental condition determines whether they are guilty or innocent, the
provision of a mental health professional is important for the defendant's defense, and the
defendant's incapacity to acquire a psychiatric testimony creates a significant danger of an
incorrect jury evaluation of the defendant's psychological state (Morse, 2021). In such
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circumstances, the absence of a mental health assessment expert and evidence can decimate a
defense; with such support, the defendant may have a decent chance of building their litigation
strategy. In such a case, when the possibility of precision of the jury's finding is greatly
increased, and where the interests of both the person and the State in an accurate procedure are
significant, the State's interests in its jurisdiction must prevail.
Rationale
The Court judged that in the Ake v. Oklahoma case, in any instance, a state uses its legal
authority against an impoverished defendant in judicial proceedings, it needs to make attempts to
ensure that the defendant gets an equal chance of arguing their case (Garrett, 2019). This basic
principle is based in part on the Constitution's due process that ensures basic fairness. The
regulations are based on the belief that justice cannot be deemed just if a defendant is denied the
opportunity to participate in legal procedures when the defendant's freedom and fair trial are at
issue only due to the defendant's financial status.
Due to the defendant's bizarre behavior in the trial court, the Supreme Court decided that
the trial court in Oklahoma erred by failing to choose a mental health specialist for a prospective
psychiatric examination the defendant may employ in their defense in a case involving the death
sentence (Groendyke, 2006). The proper judicial procedure demands the selection of a health
specialist or an expert opinion on the matter in question since it is fundamentally unjust for the
State to move forward against poor individuals without ensuring that defendants have access to
all materials necessary to build a solid defense (Garrett, 2019). The judicial authority to
designate defence specialists relies upon the competence of the defendant and their lawyer to
construct a defense against criminal accusations. Additionally, when an expert opinion is
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required to address the matter in question, and the matter is anticipated to be an important
consideration at trial and sentencing, the Court of Appeal has to choose an expert on the field in
question for the defendant.
Impact on the area of Forensic Psychology
Psychotropic medicines can have an influence on functional brain imaging, and their
effects are not necessarily temporary. The Supreme Court has emphasized the significance of
side effects in determining the scope of the right to reject mental pharmaceutical treatment. The
potential impact of antipsychotic medicines on neuropsychological data is a significant issue in
law and policy, particularly when persons have been institutionalized without their consent and
are facing criminal charges (Groendyke, 2006). Neuroimaging evidence is perceived as objective
and is expected to be accepted by jurors as tangible proof of brain disorders. If antipsychotic
drugs indeed affect brain functioning, tests on medicated defendants must be reconsidered,
particularly since such evidence may oversimplify complex psychosocial issues before the Court.
The use of involuntary medication may distort the accuracy and perception of scientific reality
based on neuroimaging evidence. Some scientists have characterized neuroimaging as merely
making pictures, raising questions about its reliability and interpretation in legal contexts.
Impact on the Criminal Justice System
In the death sentence case Ake v. Oklahoma, the Supreme Court declared that a poor
criminal defendant who demonstrates an adequate demonstration that insanity has the potential to
be a substantial factor at trial is legally eligible for the help of a psychiatrist (Bird, 2019). The
Court acknowledged that it has consistently agreed that when a state uses its judicial authority
against a poor defendant in judicial proceedings, it must make efforts to ensure that the defendant
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has a fair chance of defending their defence. This idea is based on the assurance of fundamental
fairness provided by the provision governing due process.
Conclusion
In conclusion, Ake was arraigned in Court, and because his behaviour was unusual, the
judge ordered that a psychiatrist evaluate him. Ake was found fit to stand trial, and the
proceedings resumed. The appointment of a specialist was required by the proper process since it
is essentially unfair for the State to proceed against a poor defendant without guaranteeing that
defendants have access to all the necessary materials to create a credible defense. Therefore,
Courts ensure that when a state uses its legal authority to pursue a poor individual in a criminal
action, it violates the Constitution.
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References
Bird, D. (2019). Indigent Criminal Defendants are Entitled to a Defense Team Mental Health
Expert.
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Clair, M. (2021). Being a disadvantaged criminal defendant: Mistrust and resistance in attorney-
client Interactions.
Social Forces
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(1), 194-217.
Garrett, B. L. (2019). Wealth, Equal Protection, and Due Process.
Wm. & Mary L. Rev.
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, 397.
Giannelli, P. C. (2003). Ake v. Oklahoma: The right to expert assistance in a post-Daubert, post-
DNA world.
Cornell L. Rev.
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, 1305.
Groendyke, E. J. (2006). Ake v. Oklahoma: Proposals for Making the Right a Reality.
NYUJ
Legis. & Pub. Pol'y
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10
, 367.
Morse, S. (2021). Before and after Hinckley: Legal Insanity in the United States.
U of Penn Law
School, Public Law Research Paper
, (21-08).
Pickett, M. (2023). Do Prosecutors Have a Voice in Public Defense Funding?.
Criminal
Justice
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(2), 63-64.