Law School Case Brief
Drope v. Missouri - 420 U.S. 162, 95 S. Ct. 896 (1975)
Evidence of a defendant's irrational behavior, his demeanor at trial, and any prior medical opinion on competence to stand trial are all relevant in determining whether further inquiry is required, but even one of these factors standing alone may, in some circumstances, be sufficient.
Petitioner was indicted for the forcible rape of his wife. Defense counsel filed a motion for a continuance in order that petitioner might be examined and receive psychiatric treatment. Respondent assistant circuit attorney did not oppose the motion for a psychiatric examination. No action was taken on the motion and the case proceeded to trial. During the course of the trial, petitioner shot himself in the stomach and did not appear at court. The state trial court proceeded without petitioner and a jury returned a verdict of guilty. Subsequently, the appellate court rejected petitioner's claim that he was denied due process of law by the conduct of his criminal trial in his absence and by the failure of the trial court to order a psychiatric examination. Upon writ of certiorari, the court reversed the appellate court decision and remanded the case to allow the state to retry petitioner if he was found competent to stand trial.
Did the trial court err in its failure to conduct further inquiry into the defendant's mental competency?
The court found that the trial court failed to give proper weight to the information suggesting petitioner's incompetence, and as such, the trial court should have suspended the trial until a proper evaluation of petitioner's competence was made. The defendant's due process right to a fair trial was violated by the trial court's failure to suspend the trial pending a psychiatric examination to determine the defendant's competence to stand trial, since the wife's testimony, the psychiatrist's report, and the defendant's attempted suicide were sufficient indicia of incompetency to require such examination. In view of the trial court's failure to inquire into the defendant's mental competency, there was no basis for determining whether the defendant had effectively waived his right to be present at his trial, assuming that such right could be waived. The defendant's due process rights could not be adequately protected by merely remanding for a psychiatric examination aimed at establishing whether the defendant was in fact competent at the time of the trial approximately 6 1/2 years earlier, the state being free to retry the defendant if he is competent at the time of such trial.
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