Drope v. Missouri
420 U.S. 162 (1975)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Due process requires a trial court to order a competency hearing when evidence presented before or during trial raises a sufficient doubt about a defendant's mental fitness to stand trial. The court must consider the cumulative effect of all relevant factors, including prior medical opinions, evidence of irrational behavior, and the defendant's demeanor.
Facts:
- James Drope was indicted with two others for the forcible rape of his wife.
- Before trial, Drope's counsel submitted a psychiatrist's report describing Drope as agitated, having difficulty participating, exhibiting borderline mental deficiency, and having a history of 'strange behavior' such as rolling down stairs to gain sympathy.
- During the trial, Drope's wife testified that she believed her husband was sick, needed psychiatric care, and had engaged in bizarre behavior.
- She further testified that on the Sunday evening just before the trial began, Drope had tried to choke her to death.
- On the second day of the trial, Drope did not appear in court because he had shot himself in the abdomen in a suicide attempt.
- Drope was hospitalized for three weeks to recover from his wound.
- Upon admission to the hospital, Drope stated he shot himself because of 'some problem with the law' and that he would 'rather be dead than to go to trial for something he didn’t do.'
Procedural Posture:
- James Drope was charged with rape in the Circuit Court of St. Louis, Missouri (trial court).
- Drope's counsel filed a pretrial motion for a continuance for psychiatric examination, which was not granted.
- The trial proceeded, and after Drope's mid-trial suicide attempt, the judge denied a motion for a mistrial and the trial continued in Drope's absence.
- A jury found Drope guilty, and the trial court sentenced him to life imprisonment.
- The trial court denied Drope's motion for a new trial, which argued the court erred by proceeding in his absence.
- Drope (appellant) appealed to the Missouri Supreme Court (state's highest court), which affirmed the conviction, finding his absence was voluntary.
- Drope filed a post-conviction motion to vacate the judgment in the sentencing court, raising the competence issue, which the court denied.
- Drope (appellant) appealed the denial to the Missouri Court of Appeals (intermediate appellate court), which affirmed the lower court's decision.
- The United States Supreme Court granted certiorari to review the decision of the Missouri Court of Appeals.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court's failure to order a competency hearing violate a defendant's due process rights when there is cumulative evidence raising doubt about his competence, including a pretrial psychiatric report, testimony of irrational behavior, and a mid-trial suicide attempt?
Opinions:
Majority - Mr. Chief Justice Burger
Yes. A criminal defendant is deprived of his due process right to a fair trial if the trial court fails to observe procedures adequate to protect his right not to be tried or convicted while incompetent. The Missouri courts failed to give proper weight to the aggregate of information suggesting Drope's incompetence. The pretrial psychiatric report, his wife's testimony about his irrational and violent behavior, and his bona fide suicide attempt, when considered together, created a sufficient doubt about his competence to stand trial. The trial court had a constitutional duty to suspend the trial and conduct a further inquiry into the matter, and its failure to do so was a violation of due process. Drope's absence from the trial following his suicide attempt further compounded the issue, as it deprived the judge and counsel of the ability to observe his demeanor, a key factor in assessing competence.
Analysis:
This decision clarifies and reinforces the principles established in Pate v. Robinson, emphasizing that the duty to ensure a defendant's competence is not limited to a pretrial determination but is an ongoing obligation for the court throughout the trial. It establishes that a combination of factors, including medical evidence, lay testimony of irrational acts, and a defendant's own drastic actions like a suicide attempt, can cumulatively trigger the due process requirement for a competency hearing. The case underscores that a court must consider the total picture of a defendant's mental state, as separate pieces of evidence viewed in isolation may not seem sufficient, but their aggregate effect can create the 'bona fide doubt' necessary to mandate a hearing.
Unlock the full brief for Drope v. Missouri