Supreme Court of the United States

Dusky v. United States

362 U.S. 402 · 80 S. Ct. 788 · 4 L. Ed. 2d 824

Decided April 18, 1960

Good LawGood law: 328 citing cases carry treatments with no negative treatment.

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SummaryHoldingsLater treatmentOpinion of the Court

Summary

The Court held per curiam that competency to stand trial requires sufficient present ability to consult with counsel with a reasonable degree of rational understanding and a rational as well as factual understanding of the proceedings. Orientation to time and place and some recollection of events are insufficient. Because the record did not adequately support the competency findings and retrospective determination presented difficulties, the Court reversed and remanded for a hearing on present competency and a new trial if the petitioner was found competent. There were no separate opinions.

Holdings

  • The standard for competency to stand trial.. A defendant must have sufficient present ability to consult with counsel with a reasonable degree of rational understanding and must have a rational as well as factual understanding of the proceedings. 362 U.S. 402
  • The sufficiency of the competency findings and the appropriate remedy.. The record did not sufficiently support the competency findings; a new hearing on present competency and a new trial if the petitioner was competent were required. 362 U.S. 402–403

Written by LawDiver's case analysis.

How later courts treated this case

2,697 opinions cite this case

  • Distinguished

    State ex rel. Walter Barton, Relator v. William Stange. The issue was competency to stand trial, and the standards are different and cannot be used interchangeably.

  • Distinguished

    State ex rel. Walter Barton, Relator v. William Stange. The issue was competency to stand trial, and the standards are different and cannot be used interchangeably.

  • Cited

    Calvin Neyland, Jr. v. Charlotte Jenkins. Court cites Dusky for the constitutional competency test

  • Cited

    United States v. Matthew Frazier. cited for the Dusky standard of competency

  • Cited

    People v. Lightsey. The court used this definition in stating the governing competency standard.

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In this case

Opinion of the Court

Per Curiam.

The motion for leave to proceed in forma pauperis and the petition for a writ of certiorari are granted. Upon consideration of the entire record we agree with the Solicitor General that “the record in this case does not sufficiently support the findings of competency to stand trial/' for to support those findings under 18 U. S. C. § 4244 the district judge “would need more information than this record presents.” We also agree with the suggestion of the Solicitor General that it is not enough for the district judge to find that “the defendant [is] oriented to time and place and [has] some recollection of events,” but that the “test must be whether he has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding — and whether he has a rational as well as factual understanding of the proceedings against him.”

*403 In view of the doubts and ambiguities regarding the legal significance of the psychiatric testimony in this case and the resulting difficulties of retrospectively determining the petitioner’s competency as of more than a year ago, we reverse the judgment of the Court of Appeals affirming the judgment of conviction, and remand the case to the District Court for a new hearing to ascertain petitioner’s present competency to stand trial, and for a new trial if petitioner is found competent.

It is so ordered.

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