Robert John Wolcott v. United States

407 F.2d 1149, 1969 U.S. App. LEXIS 13317
CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 11, 1969
Docket9992
StatusPublished
Cited by36 cases

This text of 407 F.2d 1149 (Robert John Wolcott v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert John Wolcott v. United States, 407 F.2d 1149, 1969 U.S. App. LEXIS 13317 (10th Cir. 1969).

Opinion

MURRAH, Chief Judge.

Petitioner Wolcott pleaded guilty to two violations of the Dyer Act in March, 1966, and was - duly sentenced. About eleven months later, he filed a § 2255 motion to set aside the sentence on the ground that he was not mentally competent to waive his constitutional rights and plead guilty. After a full evidentiary hearing, Judge Brown, the sentencing judge, found that Wolcott was mentally competent to plead guilty and denied relief. On this appeal Wolcott asserts that the trial court was aware of facts at plea and sentencing to sufficiently demonstrate the likelihood of his mental incompetence to waive his constitutional rights and plead guilty, thus requiring the court to exercise its protective duty to make further inquiry as to his mental competency; that the court improperly discharged this protective duty by relying upon personal observations, Wolcott’s answers to formal questions, and written reports instead of conducting a due process hearing; that the trial court did not cure the error by conducting a post-sentence hearing and retrospectively determining that Wolcott was competent at the time of plea and sentencing; and that the only appropriate remedy at this stage is to vacate the sentence and re-arraign the Petitioner.

We are all indeed aware of the sentencing judge’s inescapable duty to make appropriate inquiry concerning the mental responsibility of an accused for the offense charged and the mental competency to waive and plead or to stand trial on the charges against him. If the defendant’s mental responsibility for the offense is in any way put in issue, the judge must determine whether the legal presumption of criminal responsibility has been dissipated. If so, criminal responsibility becomes an essential element of the offense to be proved beyond a reasonable doubt. See Fitts v. United States, 284 F.2d 108 (10th Cir. 1960); Phillips v. United States, 311 F.2d 204 (10th Cir. 1962); Davis v. United States, 364 F.2d 572 (10th Cir. 1966). And the test for criminal responsibility in this Circuit is laid down in Wion v. United States, 325 F.2d 420 (10th Cir. 1963). See also United States v. Currens, 290 F.2d 751 (3rd Cir. 1961); Feguer v. United States, 302 F.2d 214 (8th Cir. 1962); United States v. Freeman, 357 F.2d 606 (2nd Cir. 1966) ; Pope v. United States, 372 F.2d 710 (8th Cir. 1967); United States v. Shapiro, 383 F.2d 680 (7th Cir. 1967); United States v. Chandler, 393 F.2d 920 (4th Cir. 1968).

But the threshhold issue in any case is whether an accused is mentally competent to waive his constitutional .rights and plead to the charge or stand trial, i. e., competent to understand the nature of the proceedings against him and to rationally consult with his lawyer to prepare his defense. See Dusky v. United States, 362 U.S. 402, 80 S.Ct. 788, 4 L.Ed. 824 (1960). We have always recognized the protective duty of the court to investigate as long and thoroughly as the circumstances of the case reasonably demand. The fact that an accused, informed of his rights, formally expresses a desire to waive them does not automatically end the responsibility of the *1151 court. See Snell v. United States, 174 F.2d 580 (10th Cir. 1949); Cherrie v. United States, 179 F.2d 94 (10th Cir. 1949); following Von Moltke v. Gillies, 332 U.S. 708, 68 S.Ct. 316, 92 L.Ed. 309; Miles v. United States, 385 F.2d 541 (10th Cir. 1967). But we have not always agreed whether in a given case the judge has adequately discharged his plain duty. See Ruebush v. United States, 206 F.2d 810 (10th Cir. 1953). It is this seeming contrariety which prompted us to reexamine en banc the case law in light of § 4244 and apply it to the facts of our case.

The latest word on the scope of the court’s duty to hear and decide mental competency to w'aive and plead or stand trial is Pate v. Robinson, 383 U.S. 375, 86 S.Ct. 836 (1966). That case reaffirmed the test of competency as reiterated in Dusky, supra, and further articulated the standards by which a sentencing judge shall be guided in the discharge of his highly sensitive presentence responsibilities. It is there said that if any information coming to the attention of the court raises a “bona fide doubt” of the defendant’s competency to waive his constitutional rights and plead or to stand trial, it then becomes the inescapable duty of the court to conduct a due process hearing to determine mental competency and to make appropriate findings thereon. 1 The decision is for the court and both expert and lay testimony may be competent.

The test of mental competency to waive and plead or to stand trial is “by no means the same test as those which determine criminal responsibility at the time of the crime.” See Mr. Justice Harlan in Pate v. Robinson, supra at 389, 86 S.Ct. at 844. See also James v. Boles, 339 F.2d 431 (4th Cir. 1964); United States v. Kendrick, 331 F.2d 110 (4th Cir. 1964); Lyles v. United States, 254 F.2d 725 (D.C.Cir. 1957); Feguer v. United States, supra. Indeed, an accused may be competent under Dusky, supra, to waive and plead, yet be ultimately found mentally irresponsible for the offense committed under Wion, supra. Conversely, he may be held mentally incompetent to waive and plead or to stand trial, though he may have been mentally responsible for the offense.

Judged by these precepts our issue is whether the facts developed at plea and sentencing generated a “bona fide doubt” of the defendant’s mental competency, requiring a due process hearing, and if so, whether the defendant has been accorded due process. This determination necessitates a detailed review of the competency evidence brought to the attention of the court and the court’s consideration of it.

When Wolcott appeared to plead, the judge noted that he was without counsel and appointed one.

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407 F.2d 1149, 1969 U.S. App. LEXIS 13317, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-john-wolcott-v-united-states-ca10-1969.