Wieter v. Settle (1961)

United States District Court for the Western District of Missouri, Western Division

193 F. Supp. 318

Nature of Case

Concerns the functional criteria for determining competence to stand trial and whether an incompetent defendant can be held in criminal custody when criminal prosecution is no longer probable.

Facts of Case

Kenneth Jerome Wieter was taken into federal custody on September 28, 1959 and was charged with the misdemeanor of Imparting or Conveying False Information. The United States District Court for the Southern District of California found Mr. Wieter incompetent and he was committed to the custody of the Attorney General “for hospitalization and care until such time as the defendant shall be mentally competent to stand trial or until the pending charges against him are disposed of according to law.” It was directed that he be confined in the United States Medical Center in Springfield, Missouri. He was placed in the custody of the U.S. Medical Center on January 20, 1960 and was confined for over 15 months. Mr. Wieter had been confined for a longer period of time than any possible sentence he could have received for his offense. The psychiatrists in the U.S. Medical Center were of the opinion that the defendant was unable to rationally understand the proceedings against him and cooperate with his attorney and believed his commitment should be extended. Mr. Wieter filed a petition for habeas corpus with the United States District Court for the Western District of Missouri.

Issues

Is the petitioner correct in his contention that he is being illegally detained

and should be released from his present confinement?  What specific criteria must the defendant meet in order to be found competent to stand trial in federal court?

Holding

The Court held that the petitioner could no longer be retained in federal custody, because further criminal prosecution was no longer possible. The court outlined eight functional criteria in order to determine competence to stand trial:

  1. that he has mental capacity to appreciate his presence in relation to time, place and things;
  2. that his elementary mental processes are such that he apprehends that he is in a Court of Justice, charged with a criminal offense;
  3. that there is a Judge on the Bench;
  4. a Prosecutor present who will try to convict him of a criminal charge;
  5. that he has a lawyer who will undertake to defend him against that charge;
  6. that he will be expected to tell his lawyer the circumstances, to the best of his mental ability (whether colored or not by mental aberration) the facts surrounding him at the time and place where the law violation is alleged to have been committed;
  7. that there is, or will be, a jury present to pass upon evidence adduced as to his guilt or innocence of such charge; and
  8. he has memory sufficient to relate those things in his own personal manner.

The Court reported that any psychiatric conclusion was simply an opinion and ultimately, the decision was that of the fact finder.  The Court found that the petitioner, Mr. Wieter, met the eight criteria to “the reasonable satisfaction” of the Court.

Rationale

The Court concluded that it would violate the defendant’s Sixth Amendment right to a speedy trial if the defendant was not allowed to stand trial when the defendant appeared to have the “mental faculties that would sanction their right to stand trial on the charge made against them.” The Court reported that psychiatric and legal disciplines have yet to reconcile their differences in regard to what determines competency.   The Court found that a mental illness does not equal incompetency and while the psychiatrist can offer an opinion, it is up to the fact finder to determine competency. Furthermore, if prosecution was no longer possible, an individual could not be indefinitely confined in federal criminal custody simply because the defendant was found incompetent.

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