Dezso John Lokos v. Walter Capps, Warden

625 F.2d 1258, 1980 U.S. App. LEXIS 13947
CourtCourt of Appeals for the Fifth Circuit
DecidedSeptember 18, 1980
Docket79-2771
StatusPublished
Cited by131 cases

This text of 625 F.2d 1258 (Dezso John Lokos v. Walter Capps, Warden) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dezso John Lokos v. Walter Capps, Warden, 625 F.2d 1258, 1980 U.S. App. LEXIS 13947 (5th Cir. 1980).

Opinion

REAVLEY, Circuit Judge:

On the night of December 13, 1963 Dezso John Lokos invaded the home of Leonard H. Culpepper, bound him and shot him dead, and dumped his body into a well. Lokos was tried and sentenced by the Alabama court — first to death but then commuted to life imprisonment. Further information about the crime, its repulsive perpetrator, and the 16 year old legal enterprise concerning his disposition, may be found elsewhere. 1 Our concern at this point is the competency of Lokos to stand trial in 1964. We now hold that the constitutional requirements of Pate v. Robinson, 383 U.S. 375, 86 S.Ct. 836, 15 L.Ed.2d 815 (1966), were not satisfied, and we hold that the *1260 record before the federal trial court establishes that Lokos was incompetent to be tried. The relief sought by the petitioner is finally granted.

I. THE ALABAMA TRIAL COURT (1964)

The homicide occurred near Linden, Alabama on December 13, 1963. Less than a week later Lokos was apprehended in Texas. He was returned to Alabama and charged with murder in the first degree; the trial was set for February 27, 1964. In advance of trial the appointed attorney for Lokos moved for a psychiatric examination. 2 The Alabama court conducted a hearing on the motion. Four law enforcement officers who had seen and talked to the accused during his confinement testified that they considered him sane. A medical doctor, not trained in psychiatry or psychology, who had talked to Lokos for 30 minutes and who had not considered any of his history of mental illness, testified that Lo-kos “acted sane” and knew “right from wrong”. Lokos himself testified about his history of prior psychiatric commitments and treatments.

Counsel for Lokos offered in evidence a three page letter that he had received from the director of the Winnebago State Hospital of Wisconsin which summarized Lokos’ life history, including his institutionaliza-tions, escapes and treatments. The letter advised that the entire record of Lokos was not being reproduced and mailed because it ran well over 100 pages. Highlights of the letter: Lokos entered the state hospital on July 25, 1953 under a mentally ill commitment signed by the judge of Racine County, Wisconsin. He was conditionally released on October 24, 1953 and was returned from conditional release on January 19, 1954. His diagnosis on all admissions was “Schizophrenic Reaction, Paranoid Type” and while in the hospital Lokos received both insulin shock and electro-shock therapy. “During much of the time that he was in the hospital he got along very poorly and had feelings of being persecuted here. After leaving the hospital he continued under the care of a psychiatrist in his home community.” Lokos left the hospital on a conditional release in August of 1955. The letter concluded “The long-term prognosis in this case was not very good although there was not very much evidence of an active psychotic process at the time that the boy left this hospital.”

The state trial judge refused to admit the letter into the evidence and apparently — because it was hearsay — refused to consider it for any purpose. This was probably the determinative error of the trial judge. Indicia of a defendant’s incompetence to be tried, sufficient to raise a doubt so as to require the judge to make further inquiry, need not be presented in a formal motion nor argued by defense counsel nor be presented to the judge in the form of admissible evidence. Pate v. Robinson, 383 U.S. 375, 86 S.Ct. 836, 15 L.Ed.2d 815 (1966); Drope v. Missouri, 420 U.S. 162, 95 S.Ct. 896, 43 L.Ed.2d 103 (1975). The Alabama law is in accord. Lokos v. State, 278 Ala. 586, 179 So.2d 714, 718 (1965); Buttram v. State, 338 So.2d 1062, 1064 (Cr.App.Ala. 1976).

Following the hearing, the state trial judge overruled the motion of the defend *1261 ant and said: “The court is not satisfied from the evidence submitted that the defendant was insane or that there is sufficient evidence presented to the court to even indicate insanity.”

When the trial began a week later, counsel for the defendant again asked that there be examination by an expert of the defendant, and the letter from the superintendent of the Wisconsin state hospital was again offered. The trial judge allowed the letter to be identified and included in the record but would not allow it to be read or admitted into evidence, saying “It is the same letter which has been heretofore presented to the court in another matter, and the court is familiar with it.” The judge further overruled the motion for the appointment of a psychiatrist to examine Lokos.

II. CONSTITUTIONAL GUARANTEES

A. The Substantive Right

Constitutional due process requires that trial of an accused may be conducted only when he is legally competent. Bishop v. United States, 350 U.S. 961, 76 S.Ct. 440, 100 L.Ed. 835 (1956). In Dusky v. United States, 362 U.S. 402, 80 S.Ct. 788, 4 L.Ed.2d 824 (1960), the Supreme Court wrote that the test for determining defendant’s mental competency depends upon:

[Wjhether he 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 proceeding against him. Id. at 402, 80 S.Ct. at 789.

One who has been convicted may collaterally attack that conviction by proving his incompetency at the time of the trial by a preponderance of the evidence. He is entitled to an evidentiary hearing for that purpose when he makes a showing by clear and convincing evidence to raise threshold doubt about his competency. Zapata v. Estelle, 585 F.2d 750 (5th Cir. 1978).

B. The Procedural Guarantee

State procedures must be adequate to insure the right to be tried while competent. Pate v. Robinson, 383 U.S. 375, 86 S.Ct. 836, 15 L.Ed.2d 815 (1966). A court must sua sponte conduct an inquiry into a defendant’s mental capacity if the evidence raises a bona fide doubt as to the defendant’s competency at that time. Id.; Drope v. Missouri, 420 U.S. 162, 95 S.Ct. 896, 43 L.Ed.2d 103 (1975).

A ‘‘Pate violation is a procedural error by the trial court and it may occur only in the time frame encompassed by the trial itself and immediately related proceedings. . It is always open for the defendant to later assert his actual incompetence at trial in a subsequent collateral proceeding, but the substantive claim should not be confused with a defendant’s procedural rights under

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Bluebook (online)
625 F.2d 1258, 1980 U.S. App. LEXIS 13947, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dezso-john-lokos-v-walter-capps-warden-ca5-1980.