Case Title: Gibbs v. The State
Citation: No. 30076;
235 Ga. 480;
220 S.2ed 254;
1975 Ga. LEXIS 908
Year Decided: 1975
Facts: In 1968 the defendant gave a statement to the police admitting guilt to murder. She gave this statement without a lawyer present. In court, the defendant gave an insanity plea which was accepted. As a result the defendant was committed to a mental hospital. Representatives of the state mental institution determined that the defendant could stand trial. However, the defendant was indicted again for additional murders. In addition to murdering her husband, the defendant was indicted for the murders of her three sons and grandson by the use of poison. This time, the court denied her plea to insanity and overruled the previous plea.
Issue: Did the court fail to provide the defendant with a “speedy, fair, and impartial trail”, (Gibbs v State, 1975, p. 3). Was the defendants constitutional rights violated as observed in the 5th amendment (the use of grand jury), 6th amendment (right to a public trail without unnecessary delay and impartial jury) and 14th amendment (citizenship rights and equality)?
Court Decision: The judgment of the trial court was reversed.
Holding: The plea was overruled due to prejudice observed in the grand jury, (Gibbs v State, 1975, p.3). This was observed as, the trail court systematically excluded Blacks from the grand jury. The 1974 pre-trail court denied the plea of insanity defense and the prior plea was overruled despite the defendant being White.
The court failed to provide the defendant with a “speedy, fair, and impartial trail”, (Gibbs v State, 1975, p.3). There was contradicting statements between the defendants counsel and the state mental hospital. Hospital representatives declared her fit for trail while the counsel was unable to prepare for trail due to her insanity. When the court attempted trail, the defendant was incompetent for trial and thus delayed.
1968 police statements were admitted at trail as evidence. This occurred despite the fact that the defendant was” in custody, without counsel and mentally incompetent to waive her constitutional rights”, (Gibbs v State, 1975, p. 3).
Comment: There were many instances when the defendant’s constitutional rights were violated. The higher court was fair to reverse judgment. By reading through the details of the case, the lower court did many things wrong. It is possible they were blind-sided because the defendant was accused of the murdering five people, including children. I believe the lower court wanted to apply the death penalty to this case. However, when the defendant is declared insane by the state, they become exempt from capital punishment. For this reason, the lower court wanted to bring the case to trail quickly. Doing this, the court failed to provide the defendant with a fair trial.