Pate v. Robinson, 383 U.S. 375 (1966)

Pate v. Robinson

No. 382

Argued January 26, 1966
Decided March 7, 1966
383 U.S. 375

CERTIORARI TO THE UNITED STATES COURT OF APPEALS

FOR THE SEVENTH CIRCUIT

Syllabus

Respondent was convicted in 1959 of murdering his common law wife, and given a life sentence. It was conceded at trial that he had shot and killed her, but counsel claimed that respondent was insane at the time of the incident, and also not competent to stand trial. It was uncontradicted that respondent had a long history of disturbed behavior, had been confined as a psychopathic patient, and had committed acts of violence, including the killing of his infant son and an attempted suicide. Four defense witnesses testified that respondent was insane. The trial court declined rebuttal medical testimony as to respondent’s sanity, deeming sufficient a stipulation that a doctor would testify that, when respondent was examined a few months before trial, he knew the nature of the charges and could cooperate with his counsel. The trial court’s rejection of contentions as to respondent’s sanity was challenged on appeal as a deprivation of due process of law under the Fourteenth Amendment. The State Supreme Court affirmed the conviction on the grounds that no hearing on mental capacity to stand trial had been requested and that the evidence was insufficient to require the trial court to conduct a sanity hearing sua sponte or to raise a "reasonable doubt" as to respondent’s sanity at the time of the homicide. This Court denied certiorari. The District Court denied respondent’s subsequently filed petition for writ of habeas corpus. The Court of Appeals reversed, holding that the unduly hurried trial did not provide a fair opportunity for development of facts on the insanity issues, and remanded the case to the District Court for a limited hearing as to the sanity of respondent at the time of the homicide and as to whether he was constitutionally entitled to a hearing upon his competence to stand trial.

Held:

1. The evidence raised a sufficient doubt as to respondent’s competence to stand trial so that respondent was deprived of due process of law under the Fourteenth Amendment by the trial court’s failure to afford him a hearing on that issue. Pp. 378-386.

(a) The conviction of a legally incompetent defendant violates due process. Bishop v. United States, 350 U.S. 961. P. 378.

(b) the record shows that respondent did not waive the defence of incompetence to stand trial. P. 384.

(c) In view of evidence raising a doubt on the competence issue, the court was required to impanel a jury and conduct a sanity hearing, and could not rely in lieu thereof on respondent’s demeanor at trial or on the stipulated medical testimony. Pp. 385-386.

2. In view of the difficulty of retrospectively determining the issue of an accused’s competence to stand trial (particularly where, as here, the time lapse is over six years), a hearing limited to that issue will not suffice; respondent must therefore be discharged unless the State gives him a new trial within a reasonable time. P. 387.

345 F.2d 691, affirmed in part and remanded.