Drope v. Missouri
Encyclopedia
Drope v. Missouri , , is a United States Supreme Court case in which the court decided whether a trial court deprived a defendant of due process
by failing to order a competency examination
after he was hospitalized following an attempted suicide
and as a result missed a portion of his trial for a capital offense.
of his wife, he filed a motion for a continuance
requesting psychiatric evaluation and treatment. Attached to his motion was a psychiatric report recommending psychiatric treatment. This motion was denied and the case went to trial. Drope's wife testimony confirmed Drope's strange behavior described in the psychiatric report. She also testified that Drope had tried to kill her prior to trial. On day two of the trial, Drope shot himself in an attempted suicide and was hospitalized. Although he was absent in court, the trial court denied a motion for a mistrial on the grounds that his absence was voluntary and therefore the trial should continue. The jury found Drope guilt
y and sentenced him to life imprisonment
. Drope filed a motion for a new trial on the grounds the trial court erred in continuing the trial when no evidence was offered to support that his absence was voluntary. This motion was denied based on the finding that his absence was voluntary.
The Missouri Supreme Court affirmed the decision. It also held that the trial court's denial of the motion for a continence was not an abuse of judicial discretion
. Drope's subsequent motion to vacate the conviction and sentence
, alleging, among other things, that his constitutional rights had been violated both by the court's failure to order a pretrial psychiatric evaluation and by the trial court's continuing the trial to its completion in his absence, was denied.
The Missouri Court of Appeals
also affirmed, holding that neither the psychiatric evaluation attached to Drope's motion for a continuance nor his wife's testimony raised reasonable doubt
as to his competence to proceed to trial. It further held that Drobe's suicide attempt failed to create a reasonable doubt as to his competence and that he had not demonstrated any inadequacy in the legal procedures protecting his rights. The court also affirmed the trial court's finding that his absence from the trial was voluntary.
Drope petitioned the U.S. Supreme Court on a writ
of certiorari
which the court granted based on Drope's claims that he was deprived of due process of law by the failure of the trial court to order a competency examination
to evaluate his competence to stand trial and also regarding the continuation in the defendant's absence of his trial for a capital offense.
violation.
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
by failing to order a competency examination
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
after he was hospitalized following an attempted suicide
Suicide
Suicide is the act of intentionally causing one's own death. Suicide is often committed out of despair or attributed to some underlying mental disorder, such as depression, bipolar disorder, schizophrenia, alcoholism, or drug abuse...
and as a result missed a portion of his trial for a capital offense.
Circumstances
After Drope was indicted in 1969 for the rapeRape
Rape is a type of sexual assault usually involving sexual intercourse, which is initiated by one or more persons against another person without that person's consent. The act may be carried out by physical force, coercion, abuse of authority or with a person who is incapable of valid consent. The...
of his wife, he filed a motion for a continuance
Continuance
In American procedural law, a continuance is the postponement of a hearing, trial, or other scheduled court proceeding at the request of either or both parties in the dispute, or by the judge sua sponte. In response to delays in bringing cases to trial, some states have adopted "fast-track" rules...
requesting psychiatric evaluation and treatment. Attached to his motion was a psychiatric report recommending psychiatric treatment. This motion was denied and the case went to trial. Drope's wife testimony confirmed Drope's strange behavior described in the psychiatric report. She also testified that Drope had tried to kill her prior to trial. On day two of the trial, Drope shot himself in an attempted suicide and was hospitalized. Although he was absent in court, the trial court denied a motion for a mistrial on the grounds that his absence was voluntary and therefore the trial should continue. The jury found Drope guilt
Guilt
Guilt is the state of being responsible for the commission of an offense. It is also a cognitive or an emotional experience that occurs when a person realizes or believes—accurately or not—that he or she has violated a moral standard, and bears significant responsibility for that...
y and sentenced him to life imprisonment
Life imprisonment
Life imprisonment is a sentence of imprisonment for a serious crime under which the convicted person is to remain in jail for the rest of his or her life...
. Drope filed a motion for a new trial on the grounds the trial court erred in continuing the trial when no evidence was offered to support that his absence was voluntary. This motion was denied based on the finding that his absence was voluntary.
The Missouri Supreme Court affirmed the decision. It also held that the trial court's denial of the motion for a continence was not an abuse of judicial discretion
Judicial discretion
Judicial discretion is the power of the judiciary to make some legal decisions according to their discretion. Under the doctrine of the separation of powers, the ability of judges to exercise discretion is an aspect of judicial independence...
. Drope's subsequent motion to vacate the conviction and sentence
Vacated judgment
A vacated judgment makes a previous legal judgment legally void. A vacated judgment is usually the result of the judgment of an appellate court which overturns, reverses, or sets aside the judgment of a lower court....
, alleging, among other things, that his constitutional rights had been violated both by the court's failure to order a pretrial psychiatric evaluation and by the trial court's continuing the trial to its completion in his absence, was denied.
The Missouri Court of Appeals
Missouri Court of Appeals
The Missouri Court of Appeals is the intermediate appellate court for the state of Missouri. The court handles most of the appeals from the Missouri Circuit Courts. The court is divided into three districts: Eastern The Missouri Court of Appeals is the intermediate appellate court for the state...
also affirmed, holding that neither the psychiatric evaluation attached to Drope's motion for a continuance nor his wife's testimony raised reasonable doubt
Reasonable doubt
Proof beyond a reasonable doubt is the standard of evidence required to validate a criminal conviction in most adversarial legal systems . Generally the prosecution bears the burden of proof and is required to prove their version of events to this standard...
as to his competence to proceed to trial. It further held that Drobe's suicide attempt failed to create a reasonable doubt as to his competence and that he had not demonstrated any inadequacy in the legal procedures protecting his rights. The court also affirmed the trial court's finding that his absence from the trial was voluntary.
Drope petitioned the U.S. Supreme Court on a writ
Writ
In common law, a writ is a formal written order issued by a body with administrative or judicial jurisdiction; in modern usage, this body is generally a court...
of certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
which the court granted based on Drope's claims that he was deprived of due process of law by the failure of the trial court to order a competency examination
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
to evaluate his competence to stand trial and also regarding the continuation in the defendant's absence of his trial for a capital offense.
Decision
In a unanimous decision, the Supreme Court reversed and remanded. In the decision delivered by Chief Justice Burger, four factors were considered in deciding the reversal.- The Missouri courts failed to give proper weight to the evidence suggesting petitioner's incompetence.
- Regardless of the relationship between mental illness and incompetence to stand trial, in light of the evidence presented of petitioner's behavior, including his suicide attempt, there was no opportunity to evaluate this relationship without his presence at trial. Therefore, the trial should have been suspend the until such an evaluation could be made.
- Even if the petitioner's right to be present at the trial is a right that could be waived, there was an insufficient inquiry to provide a basis for deciding the merits of the issue of such a waiver.
- The petitioner's due process rights would not be adequately protected by remanding the case for a psychiatric examination to determine whether he was, in fact, competent to stand trial in 1969. However, the State is free to retry him if he is competent to be tried at the time of another trial.
Significance
The issue of competency to stand trial is concerned with the defendant's present level of functioning; the finding of a current mental illness is not necessarily relevant to a finding of Incompetence to Stand Trial. In the current case, the Supreme Court clearly takes the position that in weighing whether any doubt exists as to the defendant's competency, the trial court must considered any evidence suggestive of mental illness, even one factor alone in some circumstances, may be sufficient to warrant an evaluation Therefore, the threshold for obtaining a competency evaluation is not very high. The court takes the position that when the issues is raised, regardless of who raises it, the motion should be granted. Further, the court suggests that it would be unconstitutional for a court to take the position that the defendant must bear all the burden for raising the issue. This has come to mean that in practice that rarely will a court refuse a request for a competency evaluation, if only to avoid a reversal by a higher court after a conviction on the grounds of a due processDue process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
violation.