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Dusky v. United States

Dusky v. United States


Dusky v. United States


One of the fundamental concepts of the United States criminal justice system is that of mens rea, or the “guilty mind.”  People who are incapable of understanding the difference between right and wrong at the time of committing a crime are not people who can have mens rea.  But what determines whether someone is classified as sane or insane for the purposes of a criminal trial?  Dusky v. United States was one of the first cases that established a standard for evaluating a defendant's competency and mental illness in the lead up to a criminal trial.


The Charges Against Dusky


Dusky and his attorneys did not dispute the basics of the charges against him.  On August 19, 1958, Dusky allowed two teenage boys to use his vehicle for the purpose of kidnapping a 15 year old girl.  They crossed over state lines into Kansas and subsequently both boys raped the girl.  Dusky tried to rape her as well but was not successful.  The girl eventually was able to escape from her captors and reported the crime to the police.


Dusky's Competence


The problem in Dusky's trial arose when his competency was evaluated.  At the time of the rape and kidnapping, both Dusky and the two minor boys had been drinking excessive amounts of alcohol.  However, even after Dusky sobered up, his attorney couldn't help but notice that he seemed almost incomprehensible.  His answers to questions didn't quite make sense, and it seemed like he wasn't really living in the same reality as everyone else.  Because of this, his attorney requested for his mental competency to be evaluated before the trial could proceed.


The defense presented arguments showing that Dusky had undifferentiated schizophrenia, which could have contributed to his behavior on August 19, 1958.  They claimed that because of the defendant's schizophrenia, actually understanding the difference between right and wrong would have been impossible.


On the other hand, the government presented a witness who had heard Dusky say that the incident would not have occurred without alcohol, and that he planned to fake mental illness if he was put on trial.  The evaluation of a psychiatrist who maintained that Dusky knew where he was and some of the factual basics of the case against him, and was therefore competent to stand trial, also went toward the government's case.  Dusky was convicted of the offenses he had been charged with, and was sentenced to 45 years in prison.


Supreme Court Ruling


In Dusky v. United States, the Supreme Court made a ruling that more than a simple factual understanding of the events that occurred is necessary to make someone competent to stand trial.  Someone who is capable of understanding and reciting basic facts may still not have a rational worldview, according to the Supreme Court, and it is this rationality that the lower courts must take into account when deciding whether someone is sane or insane for the purposes of their trial.  The conviction was overturned and Dusky v. United States was remanded to the District Court.