Spencer v. California

Background

An indigent man was convicted of murder, sentenced to death, and appealed his conviction. Before trial he pleaded not guilty and not guilty by reason of insanity. Under California law the court appointed state psychiatrists to examine him. He later withdrew the insanity plea, but the State called one appointed psychiatrist to testify about statements made during the examination.

Reasoning

The key question was whether California’s procedure treats poor and wealthy defendants differently by forcing an indigent person to submit to state psychiatric interviews whose statements can be used at trial, while private psychiatric advice for those who can pay stays privileged. Justice Goldberg argued this raises serious equal protection and due process concerns because poor defendants may be forced to choose between an insanity defense and keeping their statements private. The Supreme Court declined to review the California court’s decision, leaving the state conviction and the contested practice in place.

Real world impact

Because the Court refused review, California’s rule remains effective for now. Indigent defendants in similar situations can still face state-ordered psychiatric evaluations whose content may be admitted at trial, while paying defendants keep private evaluations confidential. The refusal to review is not a ruling on the constitutional question itself and the issue could return to the Court in a future case.

Dissents or concurrances

Justice Goldberg dissented from the refusal to review and urged the Court to consider the constitutional inequality, citing prior cases that protect fairness for accused people.