Monday, December 23, 2013

Pate v. Robinson case brief

Pate v. Robinson case brief summary
383 U.S. 375 (1966)

CASE SYNOPSIS
Respondent inmate was convicted of murder. The United States Court of Appeals for the Seventh Circuit reversed and remanded an order denying the inmate's petition for a writ of habeas corpus and directed that a hearing be held concerning the inmate's sanity. Certiorari was granted to the United States Supreme Court.

PROCEDURAL HISTORY
The appeals court directed the district court on remand to hold a hearing concerning the inmate's sanity when he committed the offense. If the inmate was found to have been insane, the district court was directed to release him.

DISCUSSION

  • The Supreme Court held that the district court's failure to make an inquiry into the inmate's competence to stand trial deprived the inmate of his constitutional right to a fair trial. 
  • The inmate did not waive the defense of incompetence to stand trial. 
  • Counsel throughout the proceedings insisted that the inmate's present sanity was an issue. 
  • The evidence introduced on the inmate's behalf entitled him to a competency hearing. 
  • The inmate was constitutionally entitled to a hearing on the issue of his competence to stand trial, but the Court did not think that there could be a meaningful hearing on the issue at such a late date.

CONCLUSION
The court affirmed the judgment of the court of appeals in part and remanded with directions to issue the inmate's writ of habeas corpus petition and discharge the inmate, unless the state gave him a new trial within a reasonable time.

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