Ake v. Oklahoma (1984)
- Docket
- 83-5424
- Decided
- 1984-01-01
Summary
Question: In capital cases, does the Fourteenth Amendment require the government to provide an indigent defendant with the psychiatric assistance necessary to prepare an effective insanity defense? Conclusion: Yes. Justice Thurgood Marshall wrote the opinion for the 8-1 majority. The Court held that, when a defendant has made a preliminary showing that his sanity at the time of the offense will be at issue during the trial, the Constitution requires the government to provide psychiatric assistance if the defendant cannot afford it. The Due Process Clause of the Fourteenth Amendment requires state-provided assistance in cases where there is a private interest that will be affected by the state’s actions, value that will be derived from the additional safeguards, and when providing the assistance will only be a minimal burden to the state. All three of these factors were present in this case. Furthermore, both justice and the Fourteenth Amendment require a defendant to be able to participate meaningfully in the judicial proceedings, which is impossible if the government were to deny this type of assistance to Ake and similar defendants. Chief Justice Warren E. Burger wrote a concurring opinion in which he noted that the Court’s decision applies only to capital cases. Justice William H. Rehnquist wrote a dissenting opinion in which he, like Justice Burger, argued that this decision should apply only to capital cases. Furthermore, he argued that this rule should provide for an independent psychiatric evaluation, not a comprehensive defense consultant.