Anderson v. United States, No. 15-2683 (7th Cir. 2017)Annotate this Case
When Anderson pleaded guilty to being a felon in possession of a firearm, the district court had only a general knowledge of Anderson’s mental‐health problems. The court knew that Anderson had been diagnosed as a paranoid schizophrenic and that he was on psychotropic medication but did not know what other illnesses Anderson had, what medication he had been prescribed, and how the drugs affected his functioning. The court also was unaware that Anderson had only spotty access to his medication while in jail awaiting trial. His appointed counsel, who had observed Anderson behaving unusually at points since his detention began, never requested a competence evaluation or hearing. Anderson’s plea agreement prevented him from directly appealing his conviction and sentence. He sought collateral relief under 28 U.S.C. 2255. The district court rejected his petition. The Seventh Circuit reversed, finding that an evidentiary hearing is necessary to consider whether he was competent at the time of his guilty plea because of his illnesses and the effects of the medications he was taking and whether his attorney provided constitutionally defective assistance for failing to challenge his competence.