Subsequent Developments
The prisoner in question, Ernest Smith, had his conviction reduced in June 1981 to 'murder with malice aforethought' and was resentenced to life imprisonment.
Although the court did not address the issue directly, it seemed to implicitly condone the practice of imposing sanctions on defendants who refuse to cooperate with state-order mental health evaluators if the defense gives notice that it intends to raise the question of the defendant's mental health as a defense. In Buchanan v. Kentucky the court found that if the defendant had raised a psychiatric defense and joined in the motion for a psychiatric evaluation, the Constitution was not violated if the prosecution used the examination results to rebut defense claims. The later ruling could be interpreted as meaning that if the defendant requests a competency evaluation, the Fifth Amendment protection is forfeited on any psychiatric issue raised as a defense.
Read more about this topic: Estelle V. Smith
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