Dusky v. United States - 362 U.S. 402, 80 S. Ct. 788 (1960)

Rule:

A Federal District Court, acting under the statute (18 USC 4244) permitting a federal court in which criminal proceedings are pending to make a finding regarding the mental competency of the accused to stand trial, may not make a determination that an accused is mentally competent merely because he is oriented to time and place and has some recollection of events; the test must be whether the accused has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and whether he has a rational as well as a factual understanding of the proceedings against him.

Facts:

Despite the psychiatric testimony showing that defendant was not competent to stand to trial, defendant was convicted of a crime in a Federal District Court after it found that the defendant was oriented to time and place and has some recollection of events. On appeal, the appellate court affirmed the conviction. Defendant’s counsel filed a motion for leave to proceed in forma pauperis and a petition for a writ of certiorari.

Issue:

Under the circumstances, should the court uphold the defendant’s conviction, notwithstanding the assertion that defendant was not competent to stand to trial?

Answer:

No.

Conclusion:

The Court found that the record of the case did not sufficiently support the findings of defendant’s competency to stand trial. According to the Court, it was not enough for the district judge to find that the defendant was oriented to time and place and has some recollection of events but that the test must be whether the defendant has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding -- and whether he has a rational as well as factual understanding of the proceedings against him. Accordingly, the judgment of the appellate court was reversed and the case was remanded to the District Court to ascertain defendant's present competency to stand trial, and for a new trial if defendant was found competent.