Frendak v. United States
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| Frendak v. United States | |
|---|---|
| Court | District of Columbia Court of Appeals |
| Full case name | Paula J. Frendak v. United States |
| Decided | October 24, 1979 |
| Citation | 408 A.2d 364 (D.C. 1979) |
| Court membership | |
| Judges sitting | John W. Kern III, George R. Gallagher, John M. Ferren |
| Case opinions | |
| Decision by | Ferren |
| Concurrence | Gallagher |
| Keywords | |
Frendak v. United States, 408 A.2d 364 (D.C. 1979) is a landmark case in which District of Columbia Court of Appeals decided that a judge could not impose an insanity defense over the defendant's objections.[1]
Paula Frendak shot a coworker. After four competency hearings, the defendant was adjudicated competent, although in the opinion of several experts she was likely insane when she committed the crime. However, Frendak refused to use the insanity defense as she felt a hospital was worse than any prison.[citation needed] She attempted suicide, went on hunger strikes and refused medication to underscore her protests.[2] However, she was forced by the court to plead insanity. Thus, in this case a competent defendant was not allowed to reject the use of the insanity defense.[3]
Decision
On appeal the decision was reversed. The judge may not impose the insanity defense upon an unwilling defendant if an intelligent defendant voluntarily wishes to forgo the defense.[4] The court said that a defendant may feel hospital is worse than prison, that the term of incarceration may be longer, that the stigma and legal consequences of a criminal or an insanity defenses are different.[3]
Using the U.S. Supreme Court decisions in North Carolina v. Alford and Faretta v. California, the court concluded that
... respect for a defendant's freedom as a person mandates that he or she be permitted to make fundamental decisions about the course of the proceedings.[5]
The court listed several disadvantages to choosing the insanity defense, including:[5]
- an insanity acquittal may increase the period of confinement over a prison sentence
- better treatment may be received in a prison than a mental hospital
- the defendant may want to avoid the stigma associated with a mental disorder
- commitment may result in loss of other rights, such as a driver's license
- the defendant may regard the crime as a political or religious act
The court therefore limited any further competence inquiry to an evaluation of the defendant's specific competency to waive the insanity defense.[5]