Vickers v. Arizona
Headline: Court denies review of a death-row inmate’s claim that the State must pay for neurodiagnostic testing for an insanity defense, leaving his conviction and the testing question unresolved.
Holding: The Court refused to review the death-row inmate’s claim that the State must provide and pay for diagnostic brain testing for an insanity defense, leaving lower-court rulings intact.
- Leaves Vickers’ conviction and death sentence in place because the Court denied review.
- Highlights unresolved question about state-funded diagnostic testing for indigent defendants.
Summary
Background
Robert Wayne Vickers, a man convicted of murdering a prison inmate and sentenced to death, argued at trial that he was insane because of possible temporal lobe epilepsy. His court-appointed psychiatrist and several other medical experts said specialized neurological testing and multiple EEGs were necessary to diagnose him, but the trial court and the Arizona Supreme Court refused to order that testing.
Reasoning
The core question raised is whether a state must provide, at public expense, the diagnostic testing needed for a court-appointed psychiatrist to evaluate an indigent defendant’s mental state when sanity is a major issue. Justice Marshall’s dissent says the Court’s earlier decision in Ake requires the State to give a defendant access to the tools the psychiatrist needs. Marshall argued that because Vickers met that showing, refusing testing unreasonably impaired his ability to present an insanity defense and entitles him to a new trial. The full Court, however, declined to review the case.
Real world impact
Because the Court denied review, the lower-court outcome stands and Vickers’ conviction and sentence remain in place for now. The broader constitutional question about whether states must pay for particular medical tests for indigent defendants thus remains unresolved by this Court and could be raised again in another case.
Dissents or concurrances
Justice Marshall, joined by Justice Brennan, dissented from the denial of review and urged the Court to hold that Ake requires state-funded diagnostic testing when sanity is a significant trial issue.
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