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Sturgeon v. Quarterman

United States Court of Appeals for the Seventh Circuit · 2009 · Criminal Procedure

Criminal ProcedureCompetency to stand trialHabeas corpusIneffective assistance of counselDue process28 U.S.C. § 2254AEDPAcompetency hearing

Facts

During lengthy pretrial proceedings on aggravated sexual assault charges, Sturgeon displayed some odd courtroom behavior, including statements about paying for a "legal injection" and claiming responsibility for the O.J. Simpson murders. In response, the state trial court ordered multiple competency evaluations by four court-appointed doctors, all of whom concluded that he was fit to stand trial, generally noting he understood the proceedings and was competent, particularly while medicated. At the guilty-plea hearing, the parties agreed the psychiatric reports found him competent to proceed as long as he remained on medication, and the judge confirmed he had taken his medication before accepting the plea. Sturgeon later sought to withdraw his plea and then pursued state postconviction relief and federal habeas relief, claiming the court should have held a competency hearing and that counsel was ineffective for not securing or raising that issue.

Issue

Whether the Illinois courts unreasonably rejected Sturgeon's claim that due process required a competency hearing because the record raised a bona fide doubt about his fitness to stand trial. Also, whether appellate counsel was ineffective for failing to raise that competency-hearing issue on direct appeal, and whether the trial-counsel claim was barred by an adequate and independent state ground.

Rule

On federal habeas review, relief may not be granted unless the state-court decision was contrary to or an unreasonable application of clearly established federal law, or rested on an unreasonable determination of the facts, and state factual findings are presumed correct absent clear and convincing evidence to the contrary. Due process requires a trial court to order a competency hearing sua sponte when there is substantial reason or a bona fide doubt as to the defendant's fitness, assessed case by case in light of irrational behavior, courtroom demeanor, and medical opinions regarding competency. A federal habeas court will not review a federal claim when the state court rejected it on an adequate and independent state procedural ground.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Milwaukee, Devin Ross was prosecuted for armed robbery. During pretrial appearances, he twice muttered that he was "already dead," but three court-appointed psychiatrists separately examined him and each concluded he understood the charges, could assist counsel, and was fit to proceed while taking prescribed medication.

On federal habeas review after conviction, Devin argues the trial judge violated due process by not ordering a competency hearing sua sponte. What is the strongest response?

Explanation. Due process requires a competency hearing only when there is substantial reason or a bona fide doubt about fitness. The majority emphasized that courts consider irrational behavior, courtroom demeanor, and medical opinions, and that unanimous expert findings of competency strongly support the conclusion that no bona fide doubt existed. On AEDPA review, the federal court asks whether the state court unreasonably applied that standard or made an unreasonable factual determination, and odd comments alone do not suffice where consistent medical evidence points the other way.