Defendant Denied Fitness Hearing Raises Issue on Appeal
In the case of People v. Doolin, the defendant was convicted of three counts of first-degree murder, one count of armed robbery, and two counts of aggravated battery with a firearm. He was sentenced to three consecutive terms of life in prison for the murders and 43 years for armed robbery.
On appeal, the defendant argued that the trial court erred in finding him fit to stand trial based on his defense counsel’s stipulations regarding his fitness. He also argued that he was denied a fair trial when the trial court incorrectly questioned prospective jurors regarding the principles outlined in Illinois Supreme Court Rule 431(b). He further raised an issue with his attorney arguing that his attorney should have stopped the polluting of the jury pool and thus he was afforded ineffective assistance of counsel. Ultimately, the court ruled that the trial court should have availed the defendant of a competency or fitness hearing to determine if he was fit to stand trial. The appeals court ultimately vacated the trial court’s fitness order and remanded the matter for a retrospective fitness hearing. Because the appeal on the grounds of the fitness order was successful, the court declined to rule on the other matters raised on appeal.
Background of the case
During trial preparations, the defendant’s attorney raised the issue of the defendant’s fitness to stand trial based on his review of records from the Social Security Administration which indicated that the defendant had vision impairments as well as mental and psychological disabilities. The circuit found that the defense counsel raised a bona fide doubt as to the defendant’s fitness to stand trial and entered an order appointing a clinical psychologist to evaluate the defendant’s fitness. The psychologist found that the defendant suffered from post-traumatic stress disorder, a mild neurocognitive disorder related to a gunshot wound to the head, mild intellectual disability, and cannabis use disorder. The psychologist offered the opinion that despite these impairments, the defendant was fit to stand trial. The defendant stipulated to the psychologist’s report and proceeded to trial on the charges.
The appeal
The United States and Illinois Constitutions both bar the prosecution of a defendant who is unfit to stand trial by reason of mental incapacity. A defendant is unfit to stand trial when he is unable to understand the nature and purpose of the proceedings against him or to assist in his own defense. Once a bona fide doubt as to the defendant’s fitness is raised, the circuit court must order a determination of the issue before proceeding further. Merely having a mental illness is not enough to render an individual unfit to stand trial. Once the trial court has ruled on the matter, the issue of fitness can only be reversed if it is “against the manifest weight of the evidence.” In this case, the appeals court took issue with the trial court’s rubber stamping of the expert’s testimony, and the failure of the court to exercise judicial discretion and judgment. Because the matter is of a constitutional nature, “the record must show an affirmative exercise of judicial discretion regarding the determination of fitness.” In this case, the court’s reliance on the expert’s testimony constituted an abuse of discretion. The matter was remanded for a second fitness hearing.
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