Anderson v. United States, 865 F.3d 914

Anderson, diagnosed with paranoid schizophrenia and other disorders, pleaded guilty in 2012 to being a felon in possession of a firearm and received a 180‑month sentence under a plea agreement that waived direct appeal but preserved collateral attacks under 28 U.S.C. § 2255.
At the plea hearing Anderson disclosed he was on psychotropic medication, said he understood proceedings "as good as I can," and gave short affirmative answers; the court accepted the plea finding him competent without probing what medications or effects he experienced.
The presentence report documented multiple psychiatric diagnoses and a medication regimen including Thorazine, Tegretol, Artane, and Ritalin, and noted Anderson had intermittent access to medications while detained.
Defense counsel observed behavioral fluctuations tied to irregular medication delivery in jail but did not request a competency evaluation before the plea; she later provided medication lists to the court at sentencing.
Anderson filed a § 2255 motion asserting (1) he was not competent to plead or be sentenced due to illness and medication effects and (2) counsel rendered ineffective assistance by failing to seek a competency hearing; the district court denied an evidentiary hearing and relief.
The Seventh Circuit granted a certificate of appealability on competence and ineffective assistance and remanded for an evidentiary hearing, concluding the record did not conclusively foreclose Anderson’s claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competence to plead guilty	Anderson lacked sufficient present ability to consult and understand due to psychotic disorder and psychotropic medication (irregularly received)	Court relied on Anderson’s affirmative colloquy answers and counsel’s general representations of competence	Court: Record lacked adequate inquiry into diagnoses, meds, and effects; remand for evidentiary hearing
Competence at sentencing	Medication irregularity and documented disorders undermined sentencing competence	District court had prior finding of competence and proceeded to sentence	Court: Sentencing competence also unresolved; hearing required to explore effects of meds and stability
Ineffective assistance for not seeking competency hearing	Counsel observed instability tied to missed meds and should have requested evaluation	Government relied on counsel’s representations that Anderson was competent when medicated	Court: Counsel’s failure raises factual questions; hearing necessary to decide deficiency and prejudice
Need for evidentiary hearing on § 2255	Anderson seeks factual development on capacity and counsel’s decisions	District court held the record conclusively showed no relief because of plea colloquy	Court: § 2255(b) standard not met by district court; remand for evidentiary hearing (petitioner’s burden is light)

Drope v. Missouri, 420 U.S. 162 (1975) (due process forbids trial of a defendant lacking mental competence)
Dusky v. United States, 362 U.S. 402 (1960) (defendant must be able to consult with counsel and have a rational and factual understanding)
Godinez v. Moran, 509 U.S. 389 (1993) (competence standard applies to pleas and to related decisions)
Strickland v. Washington, 466 U.S. 668 (1984) (framework for ineffective-assistance-of-counsel claims)
McManus v. Neal, 779 F.3d 634 (7th Cir. 2015) (use of psychotropic medication can create substantial doubt about fitness to plead)
Burt v. Uchtman, 422 F.3d 557 (7th Cir. 2005) (lack of information about a defendant’s psychotropic medication weighs in favor of a competency hearing)
Torres-Chavez v. United States, 828 F.3d 682 (7th Cir. 2016) (§ 2255 evidentiary-hearing burden is relatively light)