Mason Binion v. United States

In Pate v. Robinson, 383 U.S. 375, 384 (1966), this Court held that a trial court has an independent obligation under the Constitution to assure itself of a criminal defendant’s competency to stand trial where the defendant’s competency is in doubt. Central to this Court’s decision in Pate was the principle that “it is contradictory to argue that a defendant may be incompetent, and yet knowingly or intelligently ‘waive’ his right to have the court determine his capacity to stand trial.” Id. The Constitution thus requires trial courts to conduct procedurally “adequate” hearings for all defendants whose competency is in doubt, without regard for whether the defendant in question challenges their competency to stand trial. Id. at 378−379. The D.C. Court of Appeals vitiated these protections when it concluded that any procedural deficiencies in a competency proceeding are per se harmless when defense counsel fails to contest the defendant’s competency. The question presented is: Whether a procedurally inadequate inquiry into a criminal defendant’s competence is rendered constitutionally harmless if defense counsel does not contest competence, notwithstanding this Court’s decision in Pate that trial courts have an independent and non-waivable obligation to ensure a defendant is competent to stand trial.