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David Buchanan v. Kentucky
United States Supreme Court
483 U.S. 402 (1987)
David Buchanan (defendant), a juvenile, formed a plan to rob a gas station with another juvenile and Kevin Stanford, an adult. Stanford and Buchanan both raped the attendant. Stanford later shot the attendant twice and killed her as Buchanan watched. Buchanan was charged with murder and presented a defense of extreme emotional disturbance. Buchanan’s social worker, Martha Elam, testified on his behalf, reading from prior psychological evaluations that indicated that Buchanan had emotional and thought disturbances, was withdrawn, was depressed, had impaired judgment, and had impulse control. As rebuttal evidence, the prosecutor had Elam read from an evaluation conducted by Dr. Lange. This evaluation was jointly requested by Buchanan’s attorney and the prosecutor so that Buchanan could receive psychiatric treatment. Buchanan’s attorney objected to the introduction of Lange’s report, arguing that the report violated Buchanan’s Fifth and Sixth Amendment rights because the purpose of the report was to determine Buchanan’s competency. The judge overruled the objection and allowed Elam to read from an edited version of Lange’s report that did not discuss competency or Buchanan’s mental status when the crime was committed. Buchanan was found guilty and sentenced to life imprisonment. Buchanan appealed to the Kentucky Supreme Court. The court affirmed, finding that the judge correctly allowed the prosecutor to introduce Lange’s report on cross-examination of Elam and that even if there had been error, it was harmless. The United States Supreme Court accepted review of the case.
Rule of Law
Holding and Reasoning (Blackmun, J.)
Dissent (Marshall, J.)
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