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Law School Case Brief

Wilson v. United States - 129 U.S. App. D.C. 107, 391 F.2d 460 (1968)

Rule:

In making findings of an amnesic defendant's mental competency, the court should consider the following factors: (1) The extent to which the amnesia affected the defendant's ability to consult with and assist his lawyer. (2) The extent to which the amnesia affected the defendant's ability to testify in his own behalf. (3) The extent to which the evidence in suit could be extrinsically reconstructed in view of the defendant's amnesia. Such evidence would include evidence relating to the crime itself as well as any reasonably possible alibi. (4) The extent to which the Government assisted the defendant and his counsel in that reconstruction. (5) The strength of the prosecution's case. Most important here will be whether the Government's case is such as to negate all reasonable hypotheses of innocence. If there is any substantial possibility that the accused could, but for his amnesia, establish an alibi or other defense, it should be presumed that he would have been able to do so. (6) Any other facts and circumstances which would indicate whether or not the defendant had a fair trial. After finding all the facts relevant to the fairness of the trial, considering the amnesia, the court will then make a judgment whether, under applicable principles of due process, the conviction should stand. 

Facts:

Defendant Robert Wilson suffered from permanent retrograde amnesia as a result of a car accident that occurred shortly after he and a cohort committed armed robberies and stole a motor vehicle. Wilson was subsequently indicted on five counts of assault with a pistol and robbery. At trial in federal district court, an expert witness testified that Wilson understood the charges, but also stated that Wilson did not remember what happened on the day of the assault and robbery. The district court found that Wilson was competent to stand trial and convicted him of assault with a pistol and robbery. Wilson appealed.

Issue:

Did the trial court err in denying Wilson's motion to be adjudged incompetent to stand trial based on his condition of permanent retrograde amnesia?

Answer:

Yes.

Conclusion:

The court of appeals remanded the case to the district court for more extensive post-trial findings. The court instructed the district court to consider the following factors: (1) the extent to which the amnesia affected Wilson's ability to consult with and assist his lawyer; (2) the extent to which the amnesia affected Wilson's ability to testify in his own behalf; (3) the extent to which the evidence could have been extrinsically reconstructed in view of Wilson's amnesia; (4) the extent to which the government assisted Wilson and his counsel in that reconstruction; (5) the strength of the government's case, including whether it negated all reasonable hypotheses of innocence, and; (6) any other facts and circumstances would indicate whether Wilson had a fair trial.

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