According to the Supreme Court, People Are Assessed as Being Competent to Stand Trial if They Can
Mental Condition Requirement in Competency to Stand Trial Assessments
Abstruse
In Ohio, a criminal defendant is incompetent to stand trial only if "a nowadays mental condition" renders him unable to understand the nature and objectives of the proceedings against him or to help in his defense. Some forensic mental health evaluators take treated the mental-condition requirement as synonymous with, or similar to, the psychiatric condition required in the state's insanity criteria, which requires a "severe mental disease or defect." Notwithstanding the term mental status does not appear in other areas of the country's criminal code or in the land'south definition of a mental affliction for purposes of civil commitment. Moreover, Ohio'due south adjudicative competency statute does not explain what weather condition or symptoms constitute a mental condition sufficient to render a defendant incompetent. This article is a review of the mental condition requirement in competence to stand trial laws, using Ohio equally an example, and how this term has been interpreted (or misinterpreted) by mental health evaluators and the legal organization. Suggestions for practicing forensic evaluators are offered.
The legal system in the United States requires that criminal defendants be competent to stand trial. Trial competence protects the accused'southward right to present a defense equally guaranteed by the 6th Amendment and serves to maintain fairness in, and the dignity of, the court.i,two Rock is often quoted every bit stating that competence to stand trial "… is, in fact, the most meaning mental wellness inquiry pursued in the system of criminal law" (Ref. 3, p 200).
When the question of a defendant's competence to stand trial is raised, he is ordered by the court to undergo examination past a mental health evaluator, typically a forensic psychiatrist or psychologist. The exact legal standard for competence to stand trial varies by jurisdiction. The U.S. Supreme Court held in Dusky v. Usa that the test for competence is "whether [the defendant] has sufficient nowadays power to consult with his lawyer with a reasonable degree of rational agreement—and whether he has a rational too as factual agreement of the proceedings against him" (Ref. iv, p 402). After the Dusky conclusion, states adopted competence standards to meet the requirements set forth by the Supreme Courtroom. The Dusky conclusion, itself, did not specify that the defendant must take a mental illness or an intellectual or cognitive disability equally a prerequisite for a finding of incompetence.
In the federal system, the Insanity Defense Reform Human activity (IDRA) of 1984 states that a defendant is incompetent to stand trial if he "is presently suffering from a mental disease or defect rendering him mentally incompetent to the extent that he is unable to understand the nature and consequences of the proceedings confronting him or to help properly in his defense."5 Similarly, many country statutes include explicit language that a mental disorder, or some requisite mental condition, must be present for whatsoever finding of incompetence.1,2
Ohio'south statute on adjudicative competence states that the trial court should find a defendant incompetent to stand trial if "a preponderance of the evidence shows that, because of the defendant'southward present mental condition, the defendant is incapable of understanding the nature and objective of the proceedings confronting the defendant or of profitable in the accused's defence force, the courtroom shall find the accused incompetent to stand trial."half dozen However, nowhere in the Ohio competence statute is the term mental status further divers. This definition is distinct from the psychiatric condition required in the state's insanity statute. In Ohio, a defendant is not guilty past reason of insanity, relative to a accuse of an offense, only if he proves that at the time of the committee of the criminal offense, he did not know, as a result of a "astringent mental disease or defect," the wrongfulness of his acts.7,viii
Each state has its ain statute regarding the criteria for incompetence to stand up trial. Information technology is incumbent on the forensic evaluator to know the statute in the state where the evaluation is being conducted, and to state an opinion using correct statutory language. The American Academy of Psychiatry and the Law (AAPL) Exercise Guideline for the Forensic Psychiatric Evaluation of Competence to Stand Trial specifically addresses the demand for evaluators to know the competency standard for the jurisdiction in which the evaluation is performed.9 In our feel, still, even seasoned examiners sometimes incorrectly equate the mental-condition requirement in competence-to-stand trial assessments with the psychiatric conditions necessary in some other medicolegal assessment insanity. In this article, we discuss the potential reasons that this may occur. We also point out what may occur when evaluators drift from the correct legal standard for a given medicolegal assessment. The case of State of Ohio v. Halder is illustrative.10
State of Ohio five. Halder
The instance of Biswanath Halder stems from a nationally publicized shooting rampage that occurred in May 2003 at the Weatherhead School of Management on the campus of Instance Western Reserve Academy. Campus video surveillance revealed that Mr. Halder shot and killed the start people he encountered and thereafter fired, indiscriminately, at occupants and constabulary who arrived at the scene. He subsequently held several people earnest for almost eight hours earlier surrendering to the Cleveland Strategic Weapons and Tactics (SWAT) team.
In the form of the instance, Mr. Halder's defense squad challenged his competence to stand trial. On previous occasions, he was given diagnoses of a personality disorder, dysthymia, and low. At the competence hearing, three expert witnesses testified as to Mr. Halder's competence. Two of the 3 forensic examiners opined that Mr. Halder was not competent to stand up trial. A third examiner who had been retained by the state, whose testimony turned out to be the basis for much of Mr. Halder's postconviction appeal, opined that Mr. Halder was competent to stand trial. The court found Mr. Halder competent, and he was afterwards convicted on multiple counts, including capital murder, aggravated murder (with upper-case letter specification), and aggravated burglary. He was sentenced to life imprisonment without parole.ten
In his appeal of the verdict and sentences, Mr. Halder argued, inter alia, that the trial court erred in finding him competent to stand trial. The appellate court found no mistake in the trial court's decision that he was competent to stand trial.10 Although Mr. Halder had a astringent personality disorder that fabricated him unwilling to assist his chaser with his defense, he was competent. Of interest, even so, is how the court considered the testimony of the state'due south forensic expert.
The state'due south expert'due south diagnosis of Mr. Halder was "a severe personality disorder." The skilful stated that a person could not be found incompetent unless the person first had a diagnosed "mental disease or defect of the mind" (Ref. 10, p 33). The good opined that a personality disorder "doesn't meet the first prong to be found incompetent" (Ref. 10, p 33), because the condition is not a mental disease or defect. The defence counsel asked the good, "where [in the Ohio code] does it say mental disease or defect of the mind in regards to competence" is required? (Ref. 10 pp 33–4) In response to this line of questioning, the expert ultimately described personality disorder every bit a mental status. In other portions of the testimony, the adept described Mr. Halder'due south functional abilities in relation to his mental symptoms.
The majority opinion focused on the state adept's credentials and functional assessment, including whether Mr. Halder had the ability to assist in his defence force and a rational understanding of the proceedings, in light of his personality disorder. The fact that the court reached the question of rational understanding implies the court'southward acceptance that a personality disorder could serve as the requisite mental status nether Ohio's law.
The dissenting stance, nevertheless, focused more on the threshold legal standard and somewhat less on the functional cess: [D]efense counsel was able to get [the practiced] to admit that her "threshold outcome," used as the basis of her competency opinion, was actually the legal standard for determining sanity at the time the act was committed. … Again, the statute for determining competency to stand trial clearly does not require a "mental illness or defect of the mind." Thus, it is my view that [the expert's] opinion was based upon the wrong legal standard … (Ref. x, p 35, accent in the original).
Although the dissenting stance focused largely on the question of psychiatric threshold, information technology too noted that the country'due south skillful conceded in her testimony that "… Mr. Halder'due south power to assist his attorneys in a rational manner is impaired by virtue of the characteristics of a astringent personality disorder which interfere with his power to consider alternative viewpoints …" (Ref. 10, p. twoscore). According to the dissent, a severe personality disorder could be a qualifying mental condition for the purposes of competence to stand trial in Ohio.
Discussion
Legal Terms
The "psychiatric" component in competence to stand trial evaluations may vary by jurisdiction, both by legal term used and determination of threshold symptoms or disorders. Among others, examples of terms used in competence to stand trial statutes include mental condition,6,11 mental disorder,2 mental disease or defect,2 mental illness, defect, or disability.12 There may be no specific mental requirement included in the law, such as in Dusky.4 As examples, starting with the outset three states in alphabetical social club, Alabama's adjudicative-competence statute states: A defendant is mentally incompetent to stand trial or to be sentenced for an offense if that defendant lacks sufficient present ability in his or her defense by consulting with counsel with a reasonable degree of rational understanding of the facts and the legal proceedings confronting the defendant.xiii
Alabama'south criminal code requires that evaluating psychiatrists and psychologists include in their reports information about the "mental condition of the defendant" as it relates to the adjudicative-competence criteria. No specific mental status requirement, in the form of a psychiatric threshold status, is mentioned within the text of the competence statute itself. Alaska'due south adjudicative-competence statute, by contrast, states: A defendant who, as a issue of mental disease or defect, is incompetent because the accused is unable to understand the proceedings against the defendant or to assist in the defendant'southward own defense may not be tried, convicted, or sentenced for the commission of a criminal offence and then long every bit the incompetence exists.14
In Arizona, the adjudicative-competence statute states: "'Incompetent to stand up trial' ways that equally a result of a mental disease, defect or disability a defendant is unable to sympathize the nature and object of the proceeding or to assist in the defendant'south defence."12
In many jurisdictions, the psychiatric condition required in the country's competence to stand trial statute is different from the language used in the state's insanity statue, as in Ohio.6,–,eight In Alabama'south adjudicative-competence statute it is stated that if the examiner opines that the defendant is incompetent, the courtroom may require the examiner to give an stance regarding whether the defendant had a mental affliction or defect at the time of the alleged crime,thirteen a clear reference to a potential insanity defence force. Alabama, thus, appears to have a psychiatric threshold condition for an insanity defence, but no psychiatric threshold condition with regard to the mental condition every bit related to adjudicative competence. In law, where the legislature adopts unlike language or terms, it may be presumed that the legislature intended them to have unlike meanings. Across states, legislatures adopt laws that may share concepts or language but, ultimately, are interpreted differently. This interpretation may include similarities and differences in the wording and pregnant of a given jurisdiction'south mental-condition requirement in an adjudicative-competence statute. Grisso wrote: Virtually every land employs a legal definition of competency to stand trial patterned after the definition given by the U.Southward. Supreme Court in Dusky v. Usa (1960) … Many states accept added to this definition the requirement that deficiencies in the abilities noted in the Dusky standard must be due to "mental disorder," "mental disease or defect," or some other diction [Ref. 1, p 5].
In a more recent book, Grisso again noted that some states require that the scarce psycholegal abilities noted in Dusky must be the result of sure conditions, such as a mental disorder or mental disease or defect or, in juvenile cases, developmental immaturity.ii In Ohio, even so, it is an error for an skillful to write in a forensic report or to evidence in courtroom that a finding of incompetence to stand trial requires a mental disease or defect or a astringent mental illness.
Although states may adopt a particular term regarding a psychiatric status in their insanity statutes,7,8,13 some states leave the psychiatric disorder or condition element undefined in their adjudicative-competence statutes.6,thirteen Absent-minded a legislative (or statutory) definition, the courtroom is left to brand judicial determinations on a case-by-instance ground. In Land v. Klein, the Washington Country Supreme Court discussed this question in the context of a petition for release later a finding of insanity in Land five. Klein.fifteen
In Washington, the competence-to-stand up-trial and insanity statutes both require the presence of a mental disease or defect.16,17 In Klein, the defendant petitioned the court to determine whether her polysubstance dependence and personality disorder not otherwise specified legally constituted a mental disease or defect as required by the state'south insanity law. The courtroom said: Although our legislature has not further divers the term "mental affliction or defect," other state legislatures have. In doing so, these legislatures have exercised a legislative prerogative to depart from a dictionary definition and take instead made policy choices to exclude specific types of mental conditions from the term. Were nosotros to practice and then hither by court decision, we would unduly interlope upon the legislative function, especially since our legislature has non seen fit to further define the term [Ref. xv, pp 651–2].
Although the Klein example interpreted the state'south insanity statute, the reasoning applies in the setting of competence to stand trial.
The Klein court went on to say that the mental disease or defect is not synonymous with the term "disorder" that is found in the Diagnostic and Statistical Transmission of Mental Disorders, Fifth Edition (DSM-five).18 "Not all disorders divers therein will rise to the status of 'illness or defect' under our statutes" as the court noted that the DSM is an evolving document (Ref. 15, p 653).
The Klein courtroom added that mental health professionals may have an inclination to rely on the DSM to define any mental status or disorder, but cautioned that trial courts should not defer to mental health professionals to define legal terms. It is instructive, as well, that the DSM-5 includes a cautionary statement for forensic employ: "It is important to note that the definition of mental disorder included in the DSM-5 was adult to meet the needs of clinicians … rather than all of the technical needs of the courts and legal professionals" (Ref. 18, p 25). Although some jurisdictions have adopted the DSM for specific legal purposes, such every bit Louisiana, which specified the use of the DSM for disability assessments,nineteen its employ should not be automatically presumed by forensic mental wellness evaluators.
Further, even under the provision of the federal Insanity Defence force Reform Act5 for competence to stand trial, the excursion courts of appeals may define differently the mental disease or defect requirement of the statute. In fact, the circuits have split on whether a personality disorder may constitute a affliction or defect equally a threshold for trial incompetence. The Seventh Circuit in United States v. Rosenheimer upheld a lower courtroom's finding of competence for a defendant and stated: "the accused did non endure from any mental disease or defect, but rather from a narcissistic personality disorder which is separate and distinct from suffering from a mental illness or defect" (Ref. xx, p 112). In contrast, the 10th Excursion, in United States five. DeShazer, did non preclude a personality disorder as the footing for trial incompetence, but held that the central question is the degree of the accused's functional impairment.21 In DeShazer, despite the diagnosis of a personality disorder, the defendant could rationally aid in his defense force and cooperate with his lawyer.
Challenges for the Forensic Evaluator
The lack of specificity of mental condition and related terms in competence-to-stand-trial and other statutes may confuse and challenge legal and mental health professionals working at the police–medicine interface. Possible reasons for confusion in the terms' definitions include equating the mental/psychiatric condition requirement of competence to stand trial with that used for insanity in criminal evaluations; failure of the evaluator to appreciate jurisdictional variation in definitions for a specific forensic evaluation; examiner experience and understanding that certain major mental illnesses are more than probable than other disorders to grade the ground for trial incompetence; and the examiner personally defining the term based on what makes sense to the examiner.
In Ohio, for example, forensic examiners are commonly called on to evaluate simultaneously a person's competence to stand trial and criminal responsibility at the time of the alleged criminal deed. It is foreseeable that some forensic evaluators, so, may equate the mental status requirements in these statutes. As Ohio uses "astringent mental disease or defect" in its insanity law, examiners may conflate the terms when performing psycholegal assessments. To make things in Ohio more complicated, the state has the following additional statutory mandates regarding what must be included in a written forensic report in competence-to-stand-trial assessments: If the examiner'south opinion is that the defendant is incapable of understanding the nature and objective of the proceedings against the accused or of assisting in the defendant'southward defence force, whether the defendant soon is mentally ill or has an intellectual disability and, if the examiner'due south opinion is that the defendant presently has an intellectual disability, whether the defendant appears to be a person with an intellectual disability subject to institutionalization by courtroom lodge.11
The statute does not clarify how these additional terms are to be interpreted in light of the full general mental-status element in the competence-to-stand up-trial standard. Example law, also, has not addressed this specific question.
By non defining what constitutes a mental condition, the Ohio competence to stand up trial statute contains an element of ambiguity. The ambivalence in the definition, or lack of definition, with regard to the requisite mental status, may invite misinterpretation. Evaluators may fill in the areas of ambiguity with what makes sense to them. Conventions amidst groups of evaluators may evolve, wherein there comes to exist a belief that the legal standard specifies a psychiatric threshold condition, when in point of fact, information technology does non.
One might wonder whether land legislatures should adopt the aforementioned term (e.g., mental disorder) in all statutes that concern psychiatric symptoms or conditions. In this fashion, legal and mental health professionals could rely on the same terms and definitions and more easily employ them in a consistent manner. For instance, Washington uses mental disease or defect in both its competency-to-stand-trial and sanity statutes.16,17 Nonetheless, peradventure rational reasons be for the apply of unlike terms and definitions. Existence competent to stand trial represents a ramble right, and jurisdictions may ascertain their competency laws broadly in an effort to capture all defendants who may non be fit to proceed with the medicolegal chore. Insanity, in contrast, is a plea that typically is voluntarily made past the defence in those jurisdictions that permit an insanity defense force, and a land may choose a relatively high bar for being found insane, such as a severe mental illness or defect (in addition to fulfilling the other atmospheric condition of the state's insanity criteria). The definitions may reflect different values and policies when it comes to a defendant'south triability versus culpability.
There may exist a need for some ambiguity in the criteria for psychiatric weather condition that could issue in trial incompetence, such as in the instance of a accused with a hearing damage. In Country five. Burnett, a accused from Ohio did non use standard sign language and required multiple interpreters.22 Although the court did not explicitly comment on how the defendant's mental condition met the requirement in the state's adjudicative-competence statute, the court establish the defendant incompetent to stand trial. The courtroom relied on an expert in sign language, who opined that the defendant'due south communication was severely express, the legal proceedings were too abstract for him, and he would be likely to become confused at trial when he did not understand certain questions, which could lead to errors from the interpreters. These deficits precluded the accused from meaningfully understanding the proceedings against him and assisting in his defense force. The courtroom plainly commented that the defendant's condition was non a mental illness subject to the state's civil commitment scheme. This ruling lends support to the fact that mental illness and mental condition accept different meanings in Ohio law.
This ambiguity in terms allows for courts to consider, every bit a thing of constabulary, whether to narrow or exclude sure atmospheric condition as a basis for a detail incompetence or other evaluation. The courts and legislatures are complimentary to define the terms in the context of changes to the DSM and scientific advancement, also as a irresolute society and recognition of weather that may non meet a definition of mental illness but nevertheless may have a mental component (e.g., immaturity as a footing for juvenile adjudicative incompetence).
Diagnostic Findings
Regardless of the definition of the psychiatric condition required in any particular state competency law, inquiry shows that certain psychiatric weather condition tend to exist associated with trial incompetence. Amidst the most common conditions are psychotic illnesses and intellectual inability.
The literature indicates that current psychosis is the mental condition most associated with an examiner'due south opinion that the defendant is incompetent to stand up trial.23,–,26 Nicholson and Kugler noted that "… the correlation between psychosis and incompetence was among the highest obtained in the review" (Ref. 23, p 359), and in a meta-analysis covering 50 years of research, Pirelli et al. found "… that defendants diagnosed with a psychotic disorder were nearly 8 times more than likely to be plant incompetent than those without such a diagnosis (Ref. 24, p 16). In addition to "poor functioning on assessments of psycho-legal power," psychosis and "symptoms reflecting severe psychopathology" were highly associated with findings of incompetence to stand trial (Ref. 25, p 425).
The results of studies of intellectual inability and trial incompetence accept been mixed. Nicholson and Kugler23 described a small-scale negative correlation, merely observed that others take found the results to be just the contrary. A review commodity noted that the rates for adjudicative incompetence among persons with intellectual disability were at 12.v to 36 pct.27 The authors noted that individuals with more than severe forms of intellectual inability are more likely to exist nether abiding supervision; thus they are less probable to commit a criminal act. In our experience, individuals with milder forms of intellectual inability may exist more likely to be evaluated for adjudicative competence. Those at lower levels of intellectual disability who live in institutions may act out, merely their misbehavior may exist handled within the institution, rather than being dealt with in the legal system. At times, the legal system may choose not to prosecute individuals when incompetence to stand up trial is a very strong likelihood and when the persons involved are all being cared for in an institution. This possibility would, in upshot, delete from the equation, many individuals in the lower IQ range and, in plough, may impact the correlation between IQ and competence to stand trial.
Although one study establish that those with a diagnosis of antisocial personality disorder were associated with a finding of competence to stand trial, another study establish that some individuals with personality disorders were recommended as incompetent, although at lower rates than those with serious Axis I diagnoses.25
It appears that the psychiatric disorders associated with expert opinions and adjudications of incompetence to stand trial tend to mirror the disorders often viewed by forensic examiners as qualifying as a astringent mental disease in sanity cases. Some of the diagnoses ofttimes viewed as astringent mental affliction in the context of sanity evaluations are schizophrenia, schizoaffective disorder, schizophreniform disorder, psychotic disorder, bipolar disorder, major depression, autism spectrum disorders, and a few others.28 Clinicians may be evaluating the functional conditions that lead to an stance regarding incompetence, but these aforementioned defendants who have severe functional impairments also tend to carry the more severe clinical diagnoses.
Importance of Functional Cess
The AAPL Practice Guideline for Forensic Psychiatric Evaluation of Competence to Stand Trial9 recommends that evaluators provide a diagnosis, because in some jurisdictions, information technology is necessary to plant a mental disorder, and a diagnosis may besides aid explain the functional deficits, as well as provide a rationale for expectations of restorability. Information technology must be noted, all the same, that, rather than emphasizing a specific diagnosis, the AAPL guideline states that the about of import question in competence to stand trial evaluations is the defendant'southward ability to empathize his legal situation and to assist in his defence: the accused's and so chosen functional or psycholegal abilities. A functional cess requires that the evaluator assess the defendant's abilities and deficiencies and how these may affect the defendant's ability to participate in and understand the trial. It is useful for the forensic evaluator to comment specifically on how the defendant's deficiencies are linked to his mental status or disorder. By doing so, it provides evidence for the evaluator's opinion.
It is non uncommon, for example, for forensic evaluators to assess individuals who appear to be opposed to profitable their attorneys. Their behavior may be caused past delusional beliefs near their chaser or their office in the legal system. Alternatively, the defendant may voluntarily choose to avoid assisting his attorney because he believes that a determination of adjudicative incompetence is in his best interest and he is actively trying to be found incompetent or because he does not agree with his attorney'due south strategy for his defense force. Perhaps the most relevant question is whether at that place is a mental condition nowadays that makes the accused incapable of making a rational choice and assisting in his defense, versus whether the defendant is essentially choosing not to assist his attorney, even though he is probably capable if he choses to practice so.
Recommendations
The following recommendations for forensic evaluators are illustrated in the case nosotros have described:
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It is important to appreciate how the relevant legal linguistic communication applies to the task at hand, especially when the statutory language may exist disruptive, or fifty-fifty somewhat conflicting.
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When legal standards or terms are not clear, forensic evaluators should consult with an appropriate legal authority or peers experienced with the accustomed awarding of the relevant law in the jurisdiction.
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Forensic evaluators should non equate statutory mental health terms with DSM diagnoses unless such equation has been settled by law in the detail jurisdiction.
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The presence of a mental condition or disorder is simply one chemical element in opining on a defendant's adjudicative competence.
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Once symptoms are established or a diagnosis is made, the evaluator should focus on the accused'south functional abilities and deficiencies.
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It is important for evaluators to be articulate nearly the accused's psychiatric status, the causal connection between the status, and any deficiencies and how the deficiencies may adversely affect the accused in trial or trial preparation.
Decision
Forensic psychiatrists and psychologists deal with the interface between legal linguistic communication and concepts, and the linguistic communication and concepts of the mental health professions. We are virtually helpful to the court when we apply our specialized knowledge of personality, psychopathology, motivation, functional assessment, and other areas of mental health expertise to specific legal requirements. It is essential that mental health professionals know the relevant statutes in the jurisdiction in which the accused is charged. Psychiatrists and psychologists are particularly well qualified to assess and describe defendants' functional abilities, the crucial link to the specific psycholegal question under consideration.
Although forensic psychiatrists and psychologists are well qualified to provide assistance to the legal system, the task may, at times, exist unclear or ambiguous. This ambivalence is brought about, in role, considering statutes in different states, and even inside the aforementioned land, use different terms to specify mental condition elements. Compounding the challenges of the differing legal standards and terms is the fact that definitions of mental disease or disorder, from a psychiatric standpoint, go along to evolve, as evidenced by updates to the DSM. Different editions of the DSM reverberate different or evolving views of psychopathology and classification of disorders.29 Changes in diagnostic terminology and thinking over time may have influenced the wording in various relevant statutes, thus contributing to differences in, and defoliation regarding, the seemingly divergent statutory mental condition terms.
What is likely to continue, and to have on increasing importance in forensic evaluations, is the need for evaluators to accost the evaluee'south functional limitations in the context of his diagnosis and the specific legal question posed. Evaluators would be well served past including non only a clinical diagnosis, but too descriptions of the evaluee's abilities (and deficits) and the nexus between whatsoever deficits due to the mental condition and relevant psycholegal skills.
Footnotes
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Disclosures of financial or other potential conflicts of interest: None.
- © 2022 American University of Psychiatry and the Law
References
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Source: http://jaapl.org/content/46/1/86
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