Karl D. Roberts, Appellant v. State of Arkansas, Appellee

Summary

The court reversed the circuit court’s determination that Roberts was competent to waive postconviction relief and had the capacity to choose between life and death. Applying clear-error review, it held that the evidence of schizophrenia and the experts’ testimony left a definite and firm conviction that Roberts’s psychosis affected his ability to make a rational, knowing, and intelligent waiver. The court remanded for postconviction proceedings under Rule 37.5 and referred the question of mandatory postconviction review in capital cases to the Committee on Criminal Practice. Chief Justice Brill and Justice Goodson, dissenting, would have affirmed or remanded on narrower grounds because they would defer to the circuit court’s findings and, for Brill, require more specific findings rather than appellate fact-finding.