ANTHONY GENTILLI, PETITIONER,
v.
LOUIE L. WAINWRIGHT, DIRECTOR, DIVISION OF CORRECTIONS, RESPONDENT
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Anthony Gentilli petitioned for habeas corpus challenging his murder conviction, arguing he was incompetent to stand trial. The Florida Supreme Court held that the trial court violated Florida law by failing to conduct a statutory sanity hearing before trial, despite having reasonable grounds to question his competency and ordering psychiatric evaluation.
The trial court violated the statutory requirements of F.S. § 917.01 by failing to conduct a formal sanity hearing prior to trial, despite having reasonable grounds to question the defendant's sanity. The defendant was not afforded his substantive right to a competency determination before trial, requiring vacation of the judgment and sentence.
“That being so, the Court was required to ascertain, in the manner prescribed by the statute and prior to his trial, whether, in fact, the defendant was sane.”
Establishes the core holding that once reasonable grounds exist to question sanity, a statutory competency hearing is mandatory before trial.
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Join FLexlaw to unlock all legal intelligenceGentilli was charged with robbery and waived jury trial, pleading not guilty by reason of insanity. The trial court appointed two psychiatrists to exa…
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This cause is here for final disposition upon the petition for writ of habeas corpus and the respondent’s original and supplemental returns.
It appears the petitioner, Anthony Wayne Gentilli, was charged, in the Criminal Court of Record for Dade County, with robbery. Upon advice of counsel, he waived jury trial and pleaded not guilty by reason of insanity. The Court appointed two psychiatrists to examine petitioner but their findings are not indicated. The Court, on September 1, 1960, committed the petitioner to South Florida State Hospital where, over a period of seventeen months, he was subjected to psychiatric treatment. The commitment was in part as follows:
“It appearing unto the Court that the mental condition of the defendant, Anthony Wayne Gentillie, also known as Tony Gentilli, warrants psychiatric observation and evaluation, for which the county jail is without facilities, it is therefore * * * ordered and adjudged that the defendant * * * be received and admitted to the South Florida State Hospital for psychiatric observation, evaluation and limited treatment, if necessary, by the staff doctors of the said hospital for the period of time necessary to effect the evaluation as aforesaid * *
*420On January 31, 1962, the hospital released the petitioner for trial and advised the Court that he was then without psychosis and capable of assisting counsel in his defense. The Court did not hold a hearing to determine the defendant’s mental condition prior to his trial on June 11, 1962, following which he was sentenced to life imprisonment. Upon arrival at the state prison, the petitioner was found to be mentally incompetent and was committed to the state hospital at Chattahoochee where he is now confined.
Petitioner contends, inter alia, he was not competent to assist in his defense. Respondent’s original and supplemental returns deny that petitioner was incompetent at the time of trial and assert that, since the order committing him to the mental institution for examination was not in fact an adjudication of insanity, there was no requirement that petitioner be adjudicated sane before trial. The returns advise that the records do not reveal and the parties involved do not recollect that any action was taken pursuant to F.S. § 917.01, F.S.A.
The question is whether the requirements of F.S. § 917.01, F.S.A., were met by the Court in determining whether the defendant was competent to assist in his trial. It is apparent the Court had reasonable ground to question the sanity of the defendant. That being so, the Court was required to ascertain, in the manner prescribed by the statute and prior to his trial, whether, in fact, the defendant was sane.1 An examination of the record discloses that the requirements were not met and the petitioner was not afforded the substantive right of a sanity hearing before he was put upon trial and adjudged guilty.
The judgment and sentence are vacated and petitioner is discharged from custody thereunder. However, he shall be retained in custody by the respondent to be by him held and safely kept until further order of the appropriate court on the charge of the information pursuant to which he was originally incarcerated.2
It is so ordered.
DREW, C. J., and ROBERTS, THOR-NAL and O’CONNELL, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Brown v. State, 192 So. 2d 794 (Fla. 3d DCA 1966)…the mandatory provisions contained in subsections (a) and (b) of the statute, requiring a hearing. The appellant has also cited authorities [State ex rel. Deeb v. Fabisinski, 111 Fla. 454, 152 So. 207, 156 So. 261; Gentilli v. Wainwright, Fla.1963, 157 So. 2d 419] which relate to the mental capacity of a defendant at the time of his trial, i. e., whether he is competent to assist his counsel in the preparation of a defense. Procedures to determine sanity in this regard are governed by § 917.01, Fla.Stat., F.…
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Gibson v. State, 474 So. 2d 1183 (Fla. 1985)…sibility to conduct a hearing for competency to stand trial whenever it reasonably appears necessary, whether requested or not.” Christopher v. State, 416 So. 2d 450, 452 (Fla.1982); State v. Green, 395 So. 2d 532 (Fla.1981); Gentilli v. Wainwright, 157 So. 2d 419 (Fla.1963). Here, we find that, given Gibson’s history, the trial court should have conducted a competency hearing before proceeding to trial and predicated her conclusion on valid evidence. The Court committed reversible error by not doing so. We t…
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LEE v. Louie L. Wainwright, 457 F.2d 771 (5th Cir. 1972)…argument. However, we cannot agree with the court’s rejection of Lee’s other contention. Lee alleges that he was denied a hearing on the issue of his competence to stand trial as required by Florida law. See Gentilli v. Wainwright, Fla.Sup.Ct.1963, 157 So. 2d 419. Such an allegation, if proved, could entitle Lee to federal habeas relief. See Carroll v. Beto, 5 Cir.1970, 421 F. 2d 1065. The record before the court below was simply barren of any evidence indicating whether such a hearing was held. The record…
Authorities Cited
- Brock v. State, 69 So. 2d 344 (Fla. 1954)
- State ex rel. Fred M. FOX v. Cochran, 126 So. 2d 883 (Fla. 1961)
- LEE v. Fla. Indus. Comm'n, 122 So. 2d 179 (Fla. 1960)
- Cash v. Culver, 122 So. 2d 179 (Fla. 1960)
- Bennie Ray Hobbs v. Cochran, 143 So. 2d 481 (Fla. 1962)