213 A.3d 560
Del.2019Background
- In July 2016 Martin Taylor was arrested for the stabbing death of Whitney White; psychological evaluation diagnosed multiple serious mental disorders and noted symptoms likely present at the time of the offense.
- On October 13, 2017 Taylor pled guilty but mentally ill (GBMI) to manslaughter and a weapons offense; the Superior Court conducted a plea colloquy but deferred acceptance of the plea until sentencing pending a presentence investigation (PSI); the court and counsel agreed to bifurcate the process.
- The day after the plea Taylor asked counsel to withdraw the plea; counsel refused and advised him in writing that no legal basis supported withdrawal; Taylor filed pro se motions to withdraw, which the court declined to consider because he was represented by counsel.
- At the January 9, 2018 sentencing hearing Taylor again attempted to withdraw his plea in open court; counsel characterized Taylor’s insistence as a symptom or ‘‘fixation’’ of mental illness; the court accepted the GBMI plea and sentenced Taylor to 45 years.
- On appeal Taylor argued (1) the court violated 11 Del. C. § 408(a) by combining or improperly sequencing the statutorily required mental-illness hearing and PSI review, (2) counsel violated his Sixth Amendment autonomy by refusing to withdraw his unaccepted plea, and (3) the court erred by refusing to treat his pro se withdrawal requests.
- The Delaware Supreme Court reversed and remanded: it found waiver or harmlessness as to the scheduling/PSI issue, but held counsel and the court wrongly blocked Taylor’s right to withdraw an unaccepted plea and instructed the lower court on competency considerations on remand.
Issues
| Issue | State/Plf Argument | Taylor/Defndt Argument | Held |
|---|---|---|---|
| Whether Superior Court violated §408(a)’s “sole issue” requirement by bifurcating plea and mental-illness/PSI review | No prejudice; parties agreed to bifurcate; Taylor waived objection | Court should have held discrete mental-illness hearing after PSI and not accept plea at same hearing | Waiver and plain-error review — court did not plainly err; issue waived and any error harmless |
| Whether court failed to review “all appropriate reports” (including PSI) before adjudicating GBMI | Court reviewed available reports; Taylor didn’t cooperate with PSI | Statute requires PSI consideration before adjudication | No plain error; PSI uncompleted due to Taylor’s lack of cooperation and parties had agreed on procedure |
| Whether counsel’s refusal to withdraw an unaccepted plea violated defendant’s Sixth Amendment autonomy | Counsel acted reasonably and in defendant’s best interests | Defendant has ultimate authority to decide objective of defense, including withdrawal of unaccepted plea | Counsel violated Taylor’s autonomy; defendant has final say to withdraw plea before court acceptance |
| Whether court properly refused to consider pro se withdrawal requests while defendant represented and whether plea was voluntary under Rule 11 | Court may ignore pro se filings when defendant represented; counsel questioned Taylor’s competence | Rule 11 requires judge to satisfy plea is knowing, intelligent, voluntary; Taylor withdrew before acceptance, so plea was not voluntary | Court should have recognized withdrawal of unaccepted plea; under Rule 11 plea could not be accepted after defendant’s timely objection; remand for counsel to review withdrawal and for competency determination if needed |
Key Cases Cited
- Cooke v. State, 977 A.2d 803 (Del. 2009) (distinguishing counsel-controlled tactical choices from defendant’s personal autonomy over fundamental decisions)
- McCoy v. Louisiana, 138 S. Ct. 1500 (2018) (violation of a defendant’s autonomy over case objectives is structural error)
- Godinez v. Moran, 509 U.S. 389 (1993) (competency to plead guilty governed by Dusky standard)
- Dusky v. United States, 362 U.S. 402 (1960) (standard for competence to stand trial: rational and factual understanding and ability to consult with counsel)
- Indiana v. Edwards, 554 U.S. 164 (2008) (states may require counsel for defendants competent to stand trial but lacking capacity to conduct trial pro se)