## Facts

- Richard Allan Moran killed three people in two incidents in 1984, including two shootings at a Las Vegas saloon and the shooting of his ex-wife.
- After attempting suicide, Moran confessed to police while hospitalized.
- He was charged with three counts of first-degree murder and initially pleaded not guilty.
- Two court-appointed psychiatrists evaluated Moran and found him competent to stand trial, though both noted depression.
- Moran later sought to discharge counsel and plead guilty, stating he wanted to prevent introduction of potentially favorable evidence.
- After a colloquy, the trial court found Moran understood the charges, could assist in his defense, knowingly and intelligently waived counsel, and entered guilty pleas freely and voluntarily.
- Moran received death sentences on two counts and life without parole on the third.

## Issues

1. Whether due process requires a higher competency standard for pleading guilty or waiving counsel than for standing trial (beyond the Dusky standard).
2. Whether due process requires a separate competency hearing at the time a defendant seeks to waive counsel and plead guilty when the defendant has already been found competent to stand trial.

## Decision

- The Supreme Court reversed the Ninth Circuit.
- The Court held that the competency standard for pleading guilty and waiving the right to counsel is the same as the competency standard for standing trial under Dusky.
- The Court rejected a separate, heightened “reasoned choice” competency test for pleading guilty or waiving counsel.
- The Court held that, on these facts, due process did not require a separate competency hearing at the plea/waiver stage beyond the existing competency determination and the trial court’s colloquy.
- The case was remanded for further proceedings consistent with the Court’s ruling.

## Legal Principles

- The constitutional standard for competency to stand trial, plead guilty, and waive counsel is the Dusky test: sufficient present ability to consult with counsel with a reasonable degree of rational understanding, and a rational and factual understanding of the proceedings.
- Competency (mental capacity under Dusky) is distinct from whether a guilty plea or waiver of counsel is knowing and voluntary; both are required, but they are separate inquiries.
- The competency required to waive counsel concerns the ability to make the waiver decision, not the ability to represent oneself effectively.
- Due process does not impose a categorical requirement for a separate competency hearing at the moment of waiver of counsel or entry of a guilty plea when the defendant has already been found competent and the court conducts an adequate plea/waiver colloquy.

## Conclusion

The Court set a single constitutional competency baseline for trial, guilty pleas, and waiver of counsel under Dusky, while requiring an independent determination that any plea or waiver is knowing and voluntary, and it declined to mandate a heightened competency test or a separate competency hearing in these circumstances.


Godinez v. Moran, 509 U.S. 389 (1993)