402 F.2d 918 (3rd Cir. 1968), 17139, United States ex rel. Roberts v. Yeager

Docket Nº:17139.
Citation:402 F.2d 918
Party Name:UNITED STATES of America ex rel. Nathaniel ROBERTS, Appellant, v. Howard YEAGER, Warden, New Jersey State Prison.
Case Date:November 04, 1968
Court:United States Courts of Appeals, Court of Appeals for the Third Circuit

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402 F.2d 918 (3rd Cir. 1968)

UNITED STATES of America ex rel. Nathaniel ROBERTS, Appellant,


Howard YEAGER, Warden, New Jersey State Prison.

No. 17139.

United States Court of Appeals, Third Circuit.

November 4, 1968

Submitted on Briefs June 4, 1968.

Nathaniel Roberts, pro se.

Leo Kaplowitz, Prosecutor of Union County, Elizabeth, N.J. (Arthur J. Timins, Asst. Prosecutor, on the brief), for appellee.

Before HASTIE, Chief Judge and STALEY and SEITZ, Circuit Judges.


HASTIE, Chief Judge.

Nathaniel Roberts, a New Jersey state prisoner serving a life term pursuant to a conviction for murder, is here appealing the district court's denial of his petition for a writ of habeas corpus. Among the appellant's contentions is a claim that his conviction is invalid because he was compelled to stand trial at a time when he lacked such mental capacity as a defendant must possess in order that his trial may satisfy the constitutional standard of due process of law imposed by the Fourteenth Amendment.

The record of the state proceedings shows that neither before nor during the trial did the defendant's counsel contend that his client was incapacitated from standing trial. It was contended that the defendant had been legally irresponsible because of mental illness at the time of the homicide. Thereafter, the trial judge instructed the jury, properly under the state law, 1 that if it should find the accused not guilty because of insanity at the time of the crime it should then determine whether that condition persisted so that he should be committed to an appropriate institution. However, since the jury did not find the accused insane at the time of the homicide and did find him guilty of murder, it did not

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include in its verdict any statement concerning his mental condition at the time of trial.

Moreover, a claim that a defendant is incapable of standing trial does not present the same considerations as a claim that he was legally irresponsible for his criminal behavior, though both claims may be based upon mental aberration. In common law tradition, controversies about criminal responsibility have been resolved by inquiry into capacity to understand the nature and character of conduct and to distinguish right from wrong. In contrast, a claim of trial incapacity brings into question the ability of the accused to consult...

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