Roberts v. State

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, the court concluded that the evidence of schizophrenia and the experts’ testimony showed that Roberts’s psychosis affected his ability to make a rational, stable, 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.