383 U.S. 375 (1966), 382, Pate v. Robinson

Docket Nº:No. 382
Citation:383 U.S. 375, 86 S.Ct. 836, 15 L.Ed.2d 815
Party Name:Pate v. Robinson
Case Date:March 07, 1966
Court:United States Supreme Court

Page 375

383 U.S. 375 (1966)

86 S.Ct. 836, 15 L.Ed.2d 815




No. 382

United States Supreme Court

March 7, 1966

Argued January 26, 1966




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.


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.

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(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.

CLARK, J., lead opinion

MR. JUSTICE CLARK delivered the opinion of the Court.

In 1959, respondent Robinson was convicted of the murder of his common law wife, Flossie May Ward, and was sentenced to imprisonment for life. Being an indigent, he was defended by court-appointed counsel. It was conceded at trial that Robinson shot and killed Flossie May, but his counsel claimed that he was insane at the time of the shooting, and raised the issue of his incompetence to stand trial. On writ of error to the Supreme Court of Illinois, it was asserted that the trial court's rejection of these contentions deprived Robinson of due process of law under the Fourteenth Amendment. His conviction was affirmed, the court finding that no hearing on mental capacity to stand trial had been requested, that the evidence failed to raise sufficient doubt as to his competence to require the trial court to

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conduct a hearing on its own motion, and further that the evidence did not raise a "reasonable doubt" as to his sanity at the time of the offense. People v. Robinson, 22 Ill.2d 162, 174 N.E.2d 820 (1961). We denied certiorari. Robinson v. Pate, 368 U.S. 995 (1962). Thereupon, Robinson filed this petition for habeas corpus, which was denied [86 S.Ct. 838] without a hearing by the United States District Court for the Northern District of Illinois. The Court of Appeals reversed, United States ex rel. Robinson v. Pate, 345 F.2d 691 (1965), on the ground that Robinson was convicted in an unduly hurried trial, without a fair opportunity to obtain expert psychiatric testimony and without sufficient development of the facts on the issues of Robinson's insanity when he committed the homicide and his present incompetence. It remanded the case to the District Court with directions to appoint counsel for Robinson; to hold a hearing as to his sanity when he committed the alleged offense; and, if it found him to have been insane at that time, to order his release, subject to an examination into his present mental condition. The Court of Appeals directed that the District Court should also determine upon the hearing whether Robinson was denied due process by the state court's failure to conduct a hearing upon his competence to stand trial, and, if it were found his rights had been violated in this respect, that Robinson

should be ordered released, but such release may be delayed for a reasonable time . . . to permit the State of Illinois to grant Robinson a new trial.

345 F.2d at 698. We granted certiorari to resolve the difficult questions of state-federal relations posed by these rulings. 382 U.S. 890 (1965). We have concluded that Robinson was constitutionally entitled to a hearing on the issue of his competence to stand trial. Since we do not think there could be a meaningful hearing on that issue at this late date, we direct that the District Court, after affording the State another opportunity to put Robinson to trial on its charges within a reasonable time, order him

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discharged. Accordingly, we affirm the decision of the Court of Appeals in this respect except insofar as it contemplated a hearing in the District Court on Robinson's competence. Our disposition makes it unnecessary to reach the other reasons given by the Court of Appeals for reversal.1


The State concedes that the conviction of an accused person while he is legally incompetent violates due process, Bishop v. United States, 350 U.S. 961 (1956), and that state procedures must be adequate to protect this right. It insists, however, that Robinson intelligently waived this issue by his failure to request a hearing on his competence at the trial, and further that, on the basis of the evidence before the trial judge, no duty rested upon him to order a hearing sua sponte. A determination of these claims necessitates a detailed discussion of the conduct of the trial and the evidence touching upon the question of Robinson's competence at that time.

The uncontradicted testimony of four witnesses2 called by the defense revealed that Robinson had a long history of disturbed behavior. His mother testified that, when he was between seven and eight years of age, a brick dropped from a third floor hit Robinson on the head. "He blacked out, and the blood run from his head like a faucet." Thereafter, "he acted a little peculiar." The blow knocked him "cockeyed," and his mother took him to a specialist "to correct the crossness of his eyes." He also suffered headaches during his childhood, apparently stemming from the same event. His conduct became

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noticeably erratic about 1946 or 1947, when he was visiting his mother on a furlough from the Army. While Robinson was sitting and talking with a guest, "he jumped up and run to a [86 S.Ct. 839] bar and kicked a hole in the bar and he run up in the front." His mother asked "what on earth was wrong with him and he just stared at [her], and placed the floor with both hands in his pockets." On other occasions, he appeared in a daze, with a "glare in his eyes," and would not speak or respond to questions. In 1951, a few years after his discharge from the service, he "lost his mind and was pacing the floor saying something was after him." This incident occurred at the home of his aunt, Helen Calhoun. Disturbed by Robinson's conduct, Mrs. Calhoun called his mother about six o'clock in the morning, and she "went to see about him." Robinson tried to prevent Mrs. Calhoun from opening the door, saying "that someone was going to shoot him or someone was going to come in after him." His mother testified that, after gaining admittance,

I went to him and hugged him to ask him what was wrong, and he went to pushing me back, telling me to get back, somebody was going to shoot him, somebody was going to shoot him.

Upon being questioned as to Robinson's facial expression at the time, the mother stated that he "had that starey look, and seemed to be just a little foamy at the mouth." A policeman was finally called. He put Robinson, his mother, and aunt in a cab, which drove them to Hines Hospital. On the way, Robinson tried to jump from the cab, and, upon arrival at the hospital, he was so violent that he had to be strapped in a wheelchair. He then was taken in an ambulance to the County Psychopathic Hospital, from which he was transferred to the Kankakee State Hospital. The medical records there recited:

The reason for admission: the patient was admitted to this hospital on the 5th day of June, 1952,

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from the Hines Hospital. Patient began presenting symptoms of mental illness about a year ago, at which time he came to his mother's house. He requested money, and, when it was refused, he suddenly kicked a hole in her bar.


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