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Sieling v. Eyman - Significance, Impact

trial defendant mental capacity


Gilbert F. Sieling, Sr.


Frank A. Eyman, Warden, Arizona State Prison

Petitioner's Claim

The trial court committed a reversible error when it failed to conduct an inquiry into his mental capacity to enter a plea of guilty.

Chief Lawyer for Petitioner

Dennis J. Skarecky

Chief Lawyers for Respondent

William P. Dizon, Gary K. Nelson


Duniway, Koelsch (writing for the majority), Merrill


Los Angeles, California

Date of Decision

23 April 1973


Where a U.S. District Court in the Ninth Circuit inquires into the mental capacity of a defendant to stand trial, it also must conduct an inquiry into that defendant's mental capacity to plead guilty. Furthermore, when a questionably competent defendant pleads guilty, the standard for determining competency is higher than when the court is determining a defendant's mental capacity to stand trial.

Related Cases

  • Westbrook v. Arizona, 384 U.S. 150 (1966).
  • Boykin v. Alabama, 395 U.S. 238 (1969).
  • Schoeller v. Dunbar, 423 F. 2d 1183 (1970).
  • Godinez v. Moran, 509 U.S. 389 (1993).

Further Readings

  • Boch, Brian R. "Fourteenth Amendment--The Standard of Mental Competency to Waive Constitutional Rights Versus the Competency Standard to Stand Trial." Journal of Criminal Law and Criminology, winter/spring 1994.
  • "Competence To Plead Guilty and to Stand Trial: A New Standard When a Criminal Defendant Waives Counsel." Virginia Law Review, May 1982.
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