Sieling v. Eyman

The decision made the Ninth Circuit the first federal circuit to require that its trial courts look further into a defendant's competency to plead guilty than it looks into a defendant's capacity to stand trial.

Gilbert F. Sieling, Sr., was charged in an Arizona state court with three counts of assault with a deadly weapon and five counts of assault to commit murder. Sieling pleaded not guilty at his arraignment, and the court granted his lawyer's motion for an examination of Sieling's mental health to see if he was competent to stand trial. The two psychiatrists who examined Sieling disagreed on the question, and the court ordered a third psychiatric evaluation. At a pretrial hearing, all three psychiatrists testified that they believed Sieling was legally insane at the time he allegedly committed the crimes. On the question of Sieling's mental capacity to stand trial, the psychiatrists were split: only one believed that Sieling might be incapable of understanding the proceedings and assisting in his own defense. The finding of competency is important in a criminal trial because it decides whether the government will try to incarcerate the accused or, in the case of a mentally challenged person, commit the person to a secure mental health facility.

The court ruled that Sieling was mentally competent to stand trial and set a trial date. Shortly before trial, Sieling notified the court that he wished to change his not guilty plea to guilty. After a brief inquiry into Sieling's understanding of the charges and the consequences of the guilty plea, the court dismissed the charges of assault to commit murder, but found Sieling guilty on the counts of assault with a deadly weapon. The court ordered Sieling to serve consecutive terms of 8 to 10 and 4 to 6 years for the crimes.

Sieling later tried and failed to reverse his conviction in state court. He then filed a habeas corpus petition in a federal district court for the Ninth Circuit, arguing that his guilty pleas were invalid because the state trial court had not inquired into his competency to make the pleas. In the short colloquy that preceded his guilty plea, the trial court had only inquired into the usual matters that precede all guilty pleas: whether Sieling's plea was voluntary, whether there was any coercion from any party, and whether Sieling understood the nature of his plea. According to Sieling's attorneys, that inquiry was not enough to resolve the question of Sieling's competency to make his own plea of guilty. Indeed, the court had never made a finding on the issue of Sieling's competency to plead guilty. The district court denied his request for outright release or a rehearing, but, in April of 1973, the U.S. Court of Appeals for the Ninth Circuit reversed.

The appeals court cited the U.S. Supreme Court case of Westbrook v. Arizona (1966) as support for Sieling's argument. In that case, the trial court had found that the defendant was competent to understand the proceedings and assist his lawyer in his own defense, but the High Court held that such a finding could not stand in for a finding that the defendant was competent to proceed without a lawyer. To the Supreme Court, there was a difference between a defendant's mental competency to stand trial and a defendant's mental competency to waive a right to counsel at trial. So too, said the appeals court, was there a difference between a defendant's mental competency to stand trial and mental competency to plead guilty.

The constitutional rights involved in pleading guilty, explained the appeals court, were legion. Citing Supreme Court precedent, the appeals court noted that in pleading guilty a defendant waived the Fifth Amendment right to be free from compulsory self-incrimination and the Sixth Amendment rights to confrontation of witnesses and a trial by jury. Because so many important constitutional rights were at stake in a guilty plea, a court should, as the Supreme Court said in Boykin v. Alabama, (1969) "exercise the utmost solicitude" to ensure that a defendant who may be mentally challenged knows what he or she is doing. In a case where the defendant's mental capacity is an issue, "it is logically inconsistent to suggest that his waiver can be examined by mere reference to those criteria we examine in cases where the defendant is presumed competent."

Although the Westbrook case dealt with a defendant's waiver of counsel, which was not the specific issue in Sieling, the appeals court considered the Supreme Court's Westbrook decision ample support for its holding. The High Court did not articulate a standard for determining whether a person has enough mental capacity to intelligently waive a right to counsel, but, said the appeals court, "it is reasonable to conclude from the Court's language that the degree of competency required to waive a constitutional right is that degree which enables him to make decisions of very serious import."

Having decided that the usual inquiry into a criminal defendant's understanding and awareness were insufficient for criminal defendants who may lack sufficient mental capacity to understand the proceedings, the court needed to set a higher standard. It found the standard in the words of Judge Hufstedler in Schoeller v. Dunbar, (1970) a prior Ninth Circuit case. In Schoeller, the Ninth Circuit appeals court ruled that a defendant was competent to plead guilty at the time he was sentenced. Hufstedler, who dissented, proposed that "'[a] defendant is not competent to plead guilty if a mental illness has substantially impaired his ability to make a reasoned choice among the alternatives presented to him and to understand the nature of his plea.'" Such a standard, said that court, takes into account "the gravity of the decisions with which the defendant is faced."

The court observed that no such inquiry had taken place in Sieling's case, and that the determination was "a deficient basis for upholding a plea of guilty." It then remanded the case back to the state trial court for a determination of whether Sieling was competent to plead guilty. Before making this determination, the appeals court advised, the trial court should review the existing information from the three psychiatrists and determine whether additional information was needed to make the determination.