Pate v. Robinson
- Decided
- March 21, 1966
- Docket
- 382
- Status
- Published
- Jurisdiction
- Federal
Cited 3,039 timesNo negative treatment found in this library
What later courts said
- concluding that “the conviction of an accused person while he is legally incompetent violates due process” — Gregg v. State (2003)
- holding that failure to provide adequate procedures to ensure that the Dusky test is met deprives a defendant of his constitutional right to a fair trial — Larry Gene Hull v. Kenneth Kyler, Superintendent Pa Attorney General (1999)
- holding that a judge must provide a competency hearing on his own motion if the evidence raises a bona fide doubt as to the defendant’s competence to stand trial — United States v. Alden (2008)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
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 [*377] 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. 22 Ill. 2d 162, 174 N. E. 2d 820 (1961). We denied certiorari. 368 U. S. 995 (1962). Thereupon, Robinson filed this petition for habeas corpus, which was denied without a hearing by the United States District Court for the Northern District of Illinois. The Court of Appeals reversed, 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 [*378] 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]
I.
Cite this
Pate v. Robinson, 383 U.S. 375 (1966)Read the full opinion
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