People v. Armlin, 37 N.Y.2d 167 (1975)

Once a trial court has reason to believe a defendant may be incompetent, strict adherence to the statutory procedure for determining competency is required, and a defendant cannot waive their right to a competency hearing by pleading guilty.

Summary

Armlin was indicted on burglary and rape charges. Defense counsel, possessing medical information indicating Armlin suffered from schizophrenia and delusions, moved for a competency examination. The trial court ordered psychiatric examinations, but these orders were not fully followed, with only one psychiatrist examining Armlin. Armlin later pleaded guilty. The New York Court of Appeals held that the trial court’s failure to adhere to the statutory requirements for determining competency, specifically failing to obtain reports from two psychiatrists, deprived Armlin of a full determination of his mental capacity. The court further held that a defendant cannot waive their right to a competency hearing by pleading guilty.

Facts

Armlin was charged with burglary and rape. His counsel had medical records suggesting Armlin was a chronic schizophrenic with delusions. Prior to arraignment, Armlin’s attorney moved for a psychiatric examination to determine his competency to stand trial. The trial court initially ordered the Superintendent of Utica State Hospital to have two qualified psychiatrists examine Armlin. A subsequent order committed Armlin to Utica State Hospital for treatment, observation, examination, and a report on his mental condition. Instead of compliance with those orders, Armlin was examined by only one psychiatrist at a local mental health clinic. The psychiatrist concluded Armlin was competent, and Armlin later pleaded guilty to rape in the first degree.

Procedural History

The Fulton County Court accepted Armlin’s guilty plea and convicted him. The Appellate Division affirmed the conviction, holding that Armlin waived his right to insist on compliance with the psychiatric examination procedure by pleading guilty and not objecting to the noncompliance. One justice dissented, arguing that once the competency procedure is invoked, the court must adhere to the statutory provisions and that a defendant cannot waive the right to a competency determination. The New York Court of Appeals granted leave to appeal.

Issue(s)

1. Having found reasonable ground to believe the defendant was incapacitated, did the County Court’s failure to provide the defendant with an examination by two qualified psychiatrists, as required by CPL 730.20 (subd 1), deprive the accused of his right to a full and impartial determination of his mental capacity to stand trial?
2. By his plea of guilty, did the defendant waive his right to the proceedings mandated by CPL article 730?

Holding

1. Yes, because once the trial court has reason to believe a defendant may be incompetent, strict adherence to the statutory procedure for determining competency is required.
2. No, because a defendant cannot knowingly or intelligently waive the right to a court determination of their capacity to stand trial if they are, in fact, incompetent.

Court’s Reasoning

The Court of Appeals emphasized that while a defendant is not automatically entitled to a competency hearing, the trial court has a duty to direct an examination if there is reasonable ground to believe the defendant is incapable of understanding the proceedings. The court highlighted that the trial court’s initial orders for psychiatric examinations demonstrated sufficient concern about Armlin’s fitness. The failure to obtain reports from two qualified psychiatrists, as mandated by CPL 730.20 (subd 1), was a significant error, especially considering Armlin’s history of mental illness. Quoting People v. Smyth, 3 NY2d 184, 187, the court stated, “If at any time before final judgment in a criminal action it shall appear to the court that there is reasonable ground for believing that a defendant is in such a state of idiocy, imbecility or insanity that he is incapable of understanding the charge, indictment or proceedings or of making his defense, it is the duty of the court to direct him to be examined in these respects.”

The court rejected the argument that Armlin’s demeanor at trial could excuse the failure to comply with CPL article 730, citing Pate v. Robinson, 383 U.S. 375, 386, which held that a defendant’s demeanor cannot be relied upon to dispense with a hearing on the issue of competency. The court also rejected the argument that Armlin waived his right to competency proceedings by pleading guilty, stating, “there is an inherent contradiction in arguing that a defendant may be incompetent, and yet knowingly or intelligently waive his right to have a court determine his capacity to stand trial in accordance with the Criminal Procedure Law.” The Court of Appeals modified the order and remitted the case to the County Court for a hearing to determine whether the defendant was competent at the time of sentencing (CPL 730.20).