Supreme Court requires competency hearings in Pate v. Robinson

The Supreme Court reversed Theodore Robinson's murder conviction in Pate v. Robinson, 383 U.S. 375, holding that the due process clause requires trial courts to conduct a competency hearing whenever sufficient doubt exists about a defendant's mental fitness, even without a defense request. The Illinois trial court had refused to hold a competency hearing despite uncontradicted evidence of Robinson's long history of disturbed behavior, psychiatric confinement, and prior acts of violence. Because a meaningful retroactive hearing was impossible, the Court ordered Robinson's conviction reversed rather than remanded for a belated inquiry.