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Byron Keith Cooper v. Oklahoma
United States Supreme Court
517 U.S. 348 (1996)
Byron Keith Cooper (plaintiff) was convicted of first-degree murder and sentenced to death. During the proceedings, Cooper’s competency was raised to the judge five times. The judge initially found Cooper incompetent, but after a three-month commitment, the judge reversed the finding and determined that Cooper was competent to stand trial. Cooper’s attorney argued that Cooper was incompetent based on Cooper’s odd behavior, Cooper’s inability to communicate effectively with the attorney, and Cooper’s fear of the attorney. The judge heard testimony from a psychologist who testified that Cooper might be competent in six weeks, if treated aggressively. The judge also observed Cooper’s behavior in the courtroom, including Cooper’s refusal to change out of prison overalls, Cooper speaking to himself and a spirit, Cooper laying in a fetal position, and Cooper avoiding any contact with Cooper’s attorney. The judge ruled that Cooper was competent, as Cooper had failed to establish by clear and convincing evidence that he was incompetent. Cooper appealed, arguing that Oklahoma’s (defendant) burden of proof for incompetency violated his due-process rights under the Fourteenth Amendment. The appellate court affirmed the conviction, sentence, and competency finding. The appeals court stated that the clear and convincing standard was correct. The United States Supreme Court granted review of the case.
Rule of Law
Holding and Reasoning (Stevens, J.)
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