Yes. The court said it's not a fair fight if only the government can afford to bring in experts. If a defendant's sanity is the whole point of the defense, they need a psychiatrist to have a fair chance to defend themselves. The Constitution's promise of a fair trial means the government must provide these 'basic tools' for a defense. This also applies in death penalty cases when a prosecutor uses a psychiatrist to claim the defendant will be dangerous in the future; the defendant needs their own expert to challenge that claim.

No. This judge disagreed, arguing that Ake didn't really prove his sanity was a big issue in the first place. He thought the new rule was too broad and would cause problems. He suggested that if there is a right, it should only be for an 'unbiased' expert opinion in death penalty cases, not for a psychiatrist who acts like a personal teammate for the defense.

Yes, but only because this was a death penalty case. The Chief Justice agreed with the final decision but wanted to make it clear that this special protection exists because someone's life is on the line. He wrote separately to say that this rule might not apply to less serious crimes.

Yes. If a person on trial shows that their mental health will be a big part of their case, the government has to give them a psychiatrist to help if they can't pay for one themselves. This is necessary for a fair trial. It's especially important in cases where the death penalty is possible and the government uses psychiatrists to say the person is dangerous.

The facts here don't support creating a broad right to a free psychiatrist. Even if Ake showed his mental health was important, he should at most get an independent evaluation, not a defense consultant. This ruling should only apply to death penalty cases.

This decision is limited to the specific facts and question, which is about death penalty cases where the person's sanity at the time of the crime is a serious issue. A possible death sentence means more protections are needed than in other cases.

The Supreme Court held that, "when a defendant has made a preliminary showing that his sanity at the time of the offense is likely to be a significant factor at trial,[due process] requires that a state provide access to a psychiatrist's assistance on this issue if the defendant cannot otherwise afford one."

The Court in Ake held that "when a defendant demonstrates to the trial judge that his sanity at the time of the offense is to be a significant factor at trial, the State must, at a minimum, assure the defendant access to a competent psychiatrist who will conduct an appropriate examination and assist in evaluation, preparation, and presentation of the defense."

In Ake, the Court held that a defendant has the right to a mental health expert:(1) "when a defendant demonstrates to the trial judge that his sanity at the time of the offense is to be a significant factor at trial" and (2) "in the context of a capital sentencing proceeding, when the State presents psychiatric evidence of the defendant's future dangerousness."

Ake requires that an indigent defendant be afforded the assistance of a psychiatrist when his or her mental state is at issue.

A] criminal trial is fundamentally unfair if the State proceeds against an indigent defendant without making certain that he has access to the raw materials integral to the building of an effective defense

In addition to the right to counsel, an indigent defendant must also have a fair opportunity to present his defense.

The private interest in the accuracy of a... proceeding that places an individual's life or liberty at risk is almost uniquely compelling

"Psychiatry is not... an exact science, and psychiatrists disagree widely and frequently on what constitutes mental illness, on the appropriate diagnosis to be attached to given behavior and symptoms, on cure and treatment, and on likelihood of future dangerousness."

W] hen the resolution of the state procedural law question depends on the federal constitutional ruling, the state-law prong of the court's holding is not independent

Yes, when a defendant demonstrates that his sanity at the time of the offense will be a significant factor at trial, the state must, at a minimum, provide access to a competent psychiatrist to assist in the defense. This holding is grounded in the Fourteenth Amendment's due process guarantee of fundamental fairness, which ensures an indigent defendant has a fair opportunity to present their defense. The Court applied a three-factor balancing test, weighing 1) the individual's compelling interest in the accuracy of a criminal proceeding involving life or liberty; 2) the state's minimal economic interest against its more substantial interest in a fair and accurate adjudication; and 3) the high probable value of psychiatric assistance and the extreme risk of an inaccurate verdict without it. Furthermore, due process requires similar assistance at the sentencing phase of a capital trial if the state presents psychiatric testimony on the defendant's future dangerousness, as the defendant must have a meaningful opportunity to rebut such evidence.

No, the facts of this case do not warrant the establishment of such a broad constitutional principle. Justice Rehnquist argued that Ake failed to make a sufficient preliminary showing that his sanity was genuinely at issue, noting his detailed confession and his attorney's initial failure to request a competency hearing. He contended that the constitutional rule announced by the Court is far too broad, and if any right exists, it should be limited to capital cases and should only entitle the defendant to an independent psychiatric evaluation, not a partisan 'defense consultant.' He also viewed the majority's discussion of the sentencing phase as unnecessary dicta and noted that the defense, not the prosecution, had elicited the testimony on future dangerousness.

Yes, in this specific context, a state may not refuse an indigent defendant any opportunity to obtain psychiatric evidence when sanity is seriously at issue in a capital case. Chief Justice Burger concurred only in the judgment, emphasizing the narrow scope of the holding. He stressed that the decision is confined by the facts of the case, stating, 'In capital cases the finality of the sentence imposed warrants protections that may or may not be required in other cases. Nothing in the Court’s opinion reaches noncapital cases.'

Yes. When a defendant has made a preliminary showing that his sanity at the time of the offense is likely to be a significant factor at trial, the Constitution requires that a State provide access to a psychiatrist's assistance on this issue if the defendant cannot otherwise afford one. This is necessary for the defendant to fairly present his case within the adversary system. The Court also held that such assistance is crucial in capital sentencing proceedings where the State presents psychiatric evidence of the defendant's future dangerousness, because without it the defendant loses a significant opportunity to raise questions about the State's proof of an aggravating factor.

The facts of this case do not warrant establishing the broad constitutional right to a psychiatric expert that the majority creates. Even if Ake had made the required preliminary showing, due process at most would require an independent psychiatric evaluation, not a defense consultant. The Court's holding should be limited to capital cases.

The holding of this case is confined to the facts and question presented, specifically to capital cases where the defendant's sanity at the time of the offense is seriously in issue. The finality of a death sentence warrants protections that may not be required in other cases.

Ake v. Oklahoma

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Rule of Law:

The Legal Principle

Facts:

Procedural Posture:

How It Got Here

Issue:

Legal Question at Stake

Opinions:

Majority, Concurrences & Dissents

Analysis:

Why This Case Matters

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