From Casetext: Smarter Legal Research

Ogden v. State

Supreme Court of Nevada
Aug 18, 1980
96 Nev. 697 (Nev. 1980)

Summary

distinguishing insanity defense from competence to stand trial

Summary of this case from Jackson v. Williams

Opinion

No. 11768

August 18, 1980

Appeal from judgment of conviction; Ninth Judicial District Court, Douglas County; Howard D. McKibben, Judge.

Norman Y. Herring, Nevada State Public Defender, and J. Gregory Damm, Deputy State Public Defender, for Appellant.

Michael Smiley Rowe, District Attorney, Douglas County, for Respondent.


OPINION


The appellant seeks to have his conviction of possession of a controlled substance overturned. Three errors are assigned. First, that the trial court should have called for additional psychiatric examinations. Second, that the trial court abused its discretion in determining that the appellant was competent to stand trial. Finally, that the appellant did not make a knowing and intelligent guilty plea.

1. NRS 178.415(1) provides that the court shall appoint two physicians, at least one of whom is a psychiatrist, to examine a defendant when determining if he is competent to stand trial. In the present case, Dr. Gerow testified that Ogden was not competent to stand trial, whereas Dr. Molde testified that Ogden was competent to stand trial. When there is conflicting psychiatric testimony at a competency hearing, the trier of fact resolves the conflicting testimony of the witnesses. Doggett v. Warden, 93 Nev. 591, 572 P.2d 207 (1977). Furthermore, such findings will be sustained on appeal when substantial evidence exists to support them. Hunt v. State, 92 Nev. 536, 554 P.2d 255 (1976). Dr. Molde testified that Ogden was competent to stand trial. This testimony supports the court's decision.

NRS 178.415(1) The court shall appoint two physicians, at least one of whom is a psychiatrist or otherwise especially qualified, to examine the defendant.

2. The appellant vigorously argues that the court wrongfully relied upon a treating doctor's letter. The record does not support this assertion since the trial court expressly discounted any reliance upon any evidence other than the testimony of Dr. Gerow and Dr. Molde.

3. Finally, the appellant contends that inconclusive testimony as to his mental condition at the time of the offense precluded him from knowing whether the alternative pleas of not guilty and not guilty by reason of insanity were available to him. This contention is without merit. The medical testimony received concerned only the appellant's capacity to stand trial and was irrelevant as to his mental state at the time of the act. Competency at time of trial is not to be confused with the defense of insanity. Competency to stand trial is a judicial determination, whereas the defendant's sanity at time of commission of the act is a factual question. By pleading guilty, the appellant gave up his right to a jury trial, Duncan v. Louisiana, 391 U.S. 145 (1968), thus waiving his opportunity to raise the defense of insanity. State v. Bourdlais, 70 Nev. 233, 265 P.2d 761 (1954).

Affirmed.


Summaries of

Ogden v. State

Supreme Court of Nevada
Aug 18, 1980
96 Nev. 697 (Nev. 1980)

distinguishing insanity defense from competence to stand trial

Summary of this case from Jackson v. Williams

reviewing competency determination to see if it is supported by substantial evidence

Summary of this case from Knebl v. State

observing that competency is a question of fact and findings will be sustained if there is substantial evidence supporting them

Summary of this case from State v. O'Neill
Case details for

Ogden v. State

Case Details

Full title:JOSEPH OGDEN, APPELLANT, v. THE STATE OF NEVADA, RESPONDENT

Court:Supreme Court of Nevada

Date published: Aug 18, 1980

Citations

96 Nev. 697 (Nev. 1980)
615 P.2d 251

Citing Cases

State v. Manson

"When there is conflicting psychiatric testimony at a competency hearing," it is for the trier of fact to…

State v. Adams

"When there is conflicting psychiatric testimony at a competency hearing," it is for the trier of fact to…