People v. Stahl, 2014 IL 115804

Defendant Terris E. Stahl suffered a self-inflicted gunshot wound to the face and has complete amnesia for the events leading to charges of home invasion and aggravated unlawful restraint.
Evidence at the incident: victims’ testimony of a threatened basement hostage situation, defendant found with a facial gunshot wound, two operable firearms in the basement, and a blood trail; no fingerprint or gunshot-residue testing tying defendant to specific actions was performed.
Three psychiatrists examined Stahl: all agreed he had no memory of the charged events and substantial short-term memory deficits; two found him unfit, one (Dr. Montani) believed reasonable accommodations could permit fitness.
Trial court initially found Stahl unfit and committed him to DHS; after DHS reported restoration, a fitness-restoration hearing resulted in the court finding him still unfit and unlikely to be fit within one year.
The State appealed, arguing amnesia alone cannot render a defendant per se unfit and that, under the totality of circumstances, Stahl was fit; the appellate court affirmed and the Illinois Supreme Court granted review.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Stahl)	Held
Whether amnesia about the charged events per se renders a defendant unfit to stand trial	Amnesia alone cannot establish unfitness; statutory factors must be read as a whole	Appellate court did not hold amnesia per se dispositive; amnesia is one factor among others	Amnesia does not per se render a defendant unfit; totality of circumstances controls
Whether Stahl was fit to stand trial under the totality of circumstances	Stahl understands charges and proceedings; accommodations can mitigate short-term memory deficits	Stahl’s inability to recall the incident and severe short-term memory loss prevent him from assisting counsel and making informed decisions	Trial court’s finding that Stahl remained unfit was not against the manifest weight of the evidence; affirmed

Cooper v. Oklahoma, 517 U.S. 348 (establishes federal due-process framework for incompetency to stand trial)
Medina v. California, 505 U.S. 437 (due-process principles related to competence)
Dusky v. United States, 362 U.S. 402 (test for competency: sufficient present ability to consult with lawyer and a rational and factual understanding of proceedings)
People v. Kinkead, 182 Ill. 2d 316 (fitness must be judged under the totality of circumstances)
People v. Haynes, 174 Ill. 2d 204 (standard of review and due-process considerations for competence findings)
People v. Schwartz, 135 Ill. App. 3d 629 (amnesia alone does not automatically render defendant unfit where defendant can understand proceedings and assist counsel)
People v. Thomas, 246 Ill. App. 3d 708 (amnesia of offense day does not itself warrant finding of unfitness)
United States v. Villegas, 899 F.2d 1324 (amnesia about crime does not automatically render defendant incompetent)
United States v. Andrews, 469 F.3d 1113 (amnesia alone does not render defendant incompetent to stand trial)