People v. Bennett, 29 N.Y.2d 462 (1972)

A defendant is deprived of effective assistance of counsel and a fair trial when the defense attorney’s representation is so inadequate and ineffective as to render the trial a farce and mockery of justice due to a complete lack of investigation and preparation on the only possible defense available.

Summary

Bennett was convicted of first-degree robbery. His appeal argued ineffective assistance of counsel due to his lawyer’s failure to adequately prepare an insanity defense. The New York Court of Appeals reversed the conviction, finding that the attorney’s complete lack of preparation and investigation into Bennett’s mental state, despite a history of mental health issues, rendered the trial a farce. The court emphasized that a defendant’s right to counsel includes the right to appropriate investigations and preparation. Even though the evidence of guilt was strong, the failure to prepare the only plausible defense warranted a new trial.

Facts

Bennett, a 69-year-old man, was indicted for first-degree robbery along with a co-defendant. Before the crime, he attempted suicide and slashed his wrists while in jail. He was found incompetent to stand trial and committed to Matteawan State Hospital for about a year. After being returned from Matteawan, he was sent to Bellevue for further psychiatric observation. At trial, evidence showed Bennett was arrested fleeing the robbery scene, identified by eyewitnesses, and implicated by his co-defendant. His only potential defense was insanity at the time of the crime, given his mental health history.

Procedural History

Bennett was convicted in the Court of General Sessions and sentenced as a fourth felony offender. A notice of appeal was filed but dismissed for failure to prosecute, then reinstated. The Appellate Division affirmed the conviction, rejecting claims that the trial judge should have ordered a competency hearing and that a psychiatrist’s statement prejudiced the defendant. The New York Court of Appeals then considered the claim of ineffective assistance of counsel.

Issue(s)

Whether the defendant was deprived of effective assistance of counsel, and thus denied a fair trial, by reason of his lawyer’s manifest failure to prepare the defense that he was “insane” at the time the crime was committed.

Holding

Yes, because defense counsel demonstrated a complete lack of investigation or preparation on the only possible defense available, thereby rendering the trial a farce and a mockery of justice.

Court’s Reasoning

The court emphasized that the right to counsel means more than just having a person with a law degree present at trial. It includes conducting appropriate factual and legal investigations to determine if matters of defense can be developed, and to allow time for reflection and preparation for trial. The court highlighted the following deficiencies in the attorney’s performance: failing to read hospital records, not speaking to doctors at Bellevue or Matteawan, lacking preparation on the law vis-a-vis the insanity defense, inability to phrase the essential hypothetical question, putting psychiatrists on the stand who testified the defendant was sane, and offering hospital records that contained inadmissible and prejudicial matter. The court stated, “Clearly, then, where, as in the present case, the record unequivocally demonstrates a complete lack of investigation or preparation whatever on the only possible defense available, the lawyer, far from providing the sort of assistance which the Constitution guarantees to the most lowly defendant, has, in truth, rendered ‘the trial a farce and a mockery of justice’”. The court found this violation of the defendant’s constitutional right so gross and manifest that it could be raised for the first time on appeal. Even with strong evidence of guilt, the failure to prepare the insanity defense was so egregious as to render a guilty verdict inevitable and deny the defendant a fair trial.