Anderson v. U.S.

Dist. Ct. erred in denying defendant’s habeas petition without conducting evidentiary hearing on his claim that he lacked competency to enter into guilty plea on charge of unlawful possession of firearm, where defendant was suffering from serious mental disease at time of entry of said plea. At time of guilty plea hearing, defendant had informed Dist. Ct. that he was suffering from paranoid schizophrenia, as well as other conditions and that he was taking unspecified medications that allowed him to think clearly “as good as I can.” Moreover, presentence report indicated that defendant was suffering from three other psychological disorders that required him to take Thorazine, Tegretol and Ritalin, and his counsel reported during sentencing hearing that defendant’s behavior fluctuated over course of her representation due to jail’s inconsistent delivery of his medication. As such, defendant was entitled to evidentiary hearing to determine whether he was incompetent to enter guilty plea, since: (1) defendant’s disclosure at plea hearing of serious mental disease and his taking of unspecified medication should have alerted Dist. Ct. to possibility that defendant was not competent to enter said plea; and (2) Dist. Ct. lacked full picture of defendant’s mental condition at time of plea hearing to make any finding that defendant had capacity to enter his guilty plea. Also, hearing was required on defendant’s related claim that his counsel rendered ineffective assistance of counsel by failing to raise competency issue during plea hearing.