Godinez v. Moran, 509 U.S. 389 (1993), was a landmark decision in which the U.S. Supreme Court ruled that if a defendant was competent to stand trial, they were automatically competent to plead guilty, and thereby waive the panoply of trial rights, including the right to counsel.

[1][2] On August 2, 1984, Richard Allen Moran entered the Red Pearl Saloon in Las Vegas, Nevada and shot the bartender and a customer before robbing the cash register.

Two months after the psychiatric evaluations, Moran stated to the court that he wished to discharge his attorneys and change his plea to guilty.

Moran then sought state post conviction relief on the grounds that he was mentally incompetent to represent himself.

They reasoned that competence to stand trial requires only that the defendant have a rational and factual understanding of the proceedings and is capable of assisting his counsel, while competence to waive counsel or plead guilty requires that the defendant has the capacity for reasoned choice among those choices available.

"[5] Further, the Due Process Clause "does not mandate different standards of competency at various stages of or for different decisions made during the criminal proceedings.

"[1] As Justice Kennedy notes, this holding in Godinez v. Moran may seem harsh in equating all competencies as essentially equal.