Pate v. Robinson

In Pate v. Robinson, 383 U.S. 375 (1966), Robinson was charged with murdering his common law wife. At trial, the defense conceded that Robinson shot and killed the victim but maintained that he was insane, both when he committed the offense and at the time of trial. (Pate, supra, 383 U.S. at p. 376.) In this regard, the "uncontradicted testimony" of four witnesses established that Robinson had a long history of "disturbed behavior" and severe mental illness, that his irrational episodes became more serious with time, that the shooting of his common law wife at her place of work in front of numerous witnesses was part of a continuous course of irrational episodes, and that Robinson was still insane at the time of trial. (Id. at pp. 378-384.) Robinson's murder convictions were affirmed by the Illinois Supreme Court, who found, among other things, that the evidence did not raise a sufficient doubt about his competence to require the trial court to conduct a hearing on its own motion. (Pate, supra, 383 U.S. at p. 376-377.) The case reached the United States Supreme Court via a petition for writ of habeas corpus. The Pate court held that Robinson was constitutionally entitled to a hearing on his competence and that, because a meaningful hearing could not be held at that late date, the murder conviction had to be reversed. (Id. at p. 377.) The Pate court found, among other things, that defense counsel had placed in issue the question of Robinson's competence to stand trial by repeatedly raising the question whether Robinson was presently insane. (Pate, supra, 383 U.S. at p. 384 & fn. 6.) The court also observed that the prosecutor acknowledged there was a question as to Robinson's mental competence by making an offer of proof that a doctor who examined Robinson a few months before trial thought he was presently competent. The Pate court also rejected the state court's conclusion that evidence of "colloquies" between Robinson and the trial judge established that Robinson was mentally alert and understood the proceedings and that a competency hearing was unnecessary. According to the Pate court, such "reasoning offers no justification for ignoring the uncontradicted testimony of Robinson's history of pronounced irrational behavior." (Id. at pp. 385-386.) The Supreme Court stated that holding a retrospective hearing six years after trial would aggravate the difficulties in determining competency, and would undermine the need for a contemporaneous determination of competency. Accordingly, it held that no retrospective hearing could be conducted in that case. The court affirmed a Seventh Circuit decision which had vacated an Illinois state court conviction of a defendant who had not been afforded a hearing regarding his competence (as to which there was obvious doubt), and remanded the case to the state court for a retrial and, if then appropriate, a competency hearing. After so ruling, the court noted: "It has been pressed upon us that it would be sufficient for the state court to hold a limited hearing as to Robinson's mental competence at the time he was tried in 1959. If he were found competent, the judgment against him would stand. But we have previously emphasized the difficulty of retrospectively determining an accused's competence to stand trial. The jury would not be able to observe the subject of their inquiry, and expert witnesses would have to testify solely from information contained in the printed record. That Robinson's hearing would be held six years after the fact aggravates these difficulties." (Pate, supra, 383 U.S. at p. 387.)