28 Jul 2022

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McWilliams v. Dunn: The Case That Changed the Death Penalty

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Academic level: Master’s

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Pages: 3

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Introduction 

The Dunn vs. McWilliams case is a famous court case that was heard before the supreme court of United States in April 24, 2017. The case involved James McWilliams as the petitioner against Jefferson Dunn was the commissioner and was representing the Alabama department of corrections. The focus of the case was the sixth amendment of the US constitution was useful in providing for the right to the assistance of an attorney to represent them in defense. However the oral arguments in the case pointed out that it was unclear on whether the defendant’s right to an attorney allows for him to an independent expert who would be devoted in advocating specifically for the defense’s case.

The Controversy in the Case 

The major controversy in this popular court case arose when the petitioner, a thirty-one year old James McWilliams argued that the state should offer him with an expert mental health assistance as the constitution had provided for. This was requested in relation to the Ake v. Oklahoma, 470 U.S 68 ruling of 1985 that had approved that the defendant is allowed to have a meaningful expert assistance in the “evaluation, preparation, and presentation of the defense” 1 . However in the case argument it was realized that this clause did not clearly describe if the expert should be independent of the prosecution. The prosecution in this case was not willing to submit to this request claiming that the defendant needed only access to an expert. The prosecution was against the idea of the defendant being offered an independent expert but they wanted the judge to allow provision of an expert who would be neutral to all parties involved in the case.

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Process of the case before reaching Supreme Court 

Initially, McWilliams had been arrested of raping and murdering a store attendant in 1985. This was just one month after the Ake v. Oklahoma case was decided. The Alabama magistrate court appointed a counsel to serve in trial and he requested a psychiatric examination of the defendant (McWlliams). The state through prosecution claimed that the defendant was able to stand trial and he was in good condition when committing the offense. The prosecution was of the argument that McWilliams was not suffering from mental illness and this would not interfere with his capability to stand trial.

The court found McWilliams guilty of capital murder and was bound to hand him a death sentence. Prior to the court ruling the counsel representing the defendant, asked for an opportunity to have McWilliams undergo neurological and neuropsychological test. The request was allowed by the judge and Dr. John Goff was tasked with examining the defendant. Just before the judicial sentence hearing the doctor filed a report claiming that the defendant was actually suffering from some genuine neuropsychological problems though he was exaggerating the signs. The same was confirmed by the Alabama department of corrections that confirmed McWilliams was suffering from mental health issues. The medical reports claimed that MCwilliams was “extremely disturbed, has much internal anxiety and likely had a serious pathology.” 2 The court held to its initial decision of sentencing him to death for committing rape and murder.

Upon appeal at the Alabama Court of Criminal Appeals the judges upheld the earlier ruling claiming that Dr. Goffs testing and examination satisfied the Akes requirements. McWilliams through his attorney had argued that the trial court failed to offer him a right to meaningful expert assistance as provided by law.

The Supreme Court Ruling 

The majority opinion on the McWilliams case admitted that the defendant was actually an ‘Indigent defendant’ and his mental condition was relevant to the punishment he might suffer. The court also admitted that the defendants’ sanity at time of offense was an important consideration during the court trial. The judges held that the Ake requirement allowed for “access to a competent psychiatrist who would conduct an appropriate examination and assistance in evaluation preparation and presentation of the defense 3 .

The minority group who were opposing the ruling observed that there was unwillingness to resolve on the issue of offering the right to an expert independent form the prosecution. There was an opinion that the court was not willing to go into details of reviewing of all the provisions of the Ake law that would allow for the determination whether it was clear the defendant should be offered assistance of a mental health expert who is sufficiently available to the defense and independent for the prosecution.

The Reasoning behind the Supreme Court Decision 

The Supreme Court reversed the decision of the court of appeal and the case was remanded for further proceedings. The Supreme Court felt that the lower courts were holding on errors and were wide diverging from the establishment of the law. However there was an opinion that the courts error was not substantial and injurious to warrant a grant of habeas relief. The court observed that the court was wring on holding to the idea that the Ake law requirements was satisfactorily met by providing the defendant with a competent psychiatrist 4 . The Supreme Court reported that the Ake law does not only provide for examination but it should also allow for “access to a competent psychiatrist who will conduct an appropriate examination and assist in evaluation preparation, and presentation of the defense 5 .

Conclusion 

The Supreme Court ruling has affected Americans lives considering the fact that numerous states show support for a requirement that indigent defendants in criminal cases b granted independent mental health expert. Therefore people in criminal cases would find relief by being offered an independent expert. This would serve in improving examination, preparation and presentation of defense. The cases will now have better direction despite the fact that defendant might be psychologically unstable. The decisions would also serve bring clarity to law and ensure that the lower courts sufficiently understood the law before making decisions. The ruling also serves to eliminate widespread disagreement between law interpreters and enforcers. Personally the case has made me understand how disagreement in law issues can occur and make people to suffer underserved punishment.

Bibliography 

Carens Liza & Cohen Scott. McWilliams V Dunn . Supreme Court bulletin. 2017

Morse, Stephen. "Mental Disorder and Criminal Justice." (2017).

Morse, Stephen. "Involuntary Competence in United States Criminal Law." (2017).

Wynne, Susan. "Indigent defense in the United States: An analysis of state frameworks for ensuring the effective assistance of counsel." PhD diss., 2017.

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StudyBounty. (2023, September 15). McWilliams v. Dunn: The Case That Changed the Death Penalty.
https://studybounty.com/mcwilliams-v-dunn-the-case-that-changed-the-death-penalty-essay

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