People v. Brown
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Brown was charged with armed robbery and aggravated robbery. At a pretrial conference, defense counsel stated that Brown had told counsel that “a mental problem that he has had in the past has resurfaced. He’s under medication.... He tells me that he is again starting to hear the voices and said that he was having some difficulty in communicating with me … and that it may have factored into the events ... it may be necessary to do an evaluation to determine whether or not he’s fit to stand trial.” Judge Kouri ordered an evaluation, continuing the case for 30 days. The attorneys indicated the “evaluation would just be for fitness.” The fitness report indicated that Brown met the DSM-5 criteria for schizoaffective disorder, bipolar type; PTSD; and mild intellectual disability but had the ability to understand the nature and purpose of the proceedings and to assist in his defense. At the next court date, a written order set the matter for trial and included handwritten notations, “fitness report received, parties stipulate to contents” and “by agreement—Brown is fit to stand trial.” Brown was convicted.
The appellate court reversed, finding that the trial court failed to affirmatively exercise its judicial discretion to determine Brown’s fitness for trial. The Illinois Supreme Court reinstated the verdict and sentence. Neither the parties nor the trial court indicated a bona fide doubt of Brown’s fitness, either when Judge Kouri ordered the examination or 30 days later. No party ever requested a fitness hearing. Absent a bona fide doubt concerning his fitness to stand trial, Brown was not entitled to a fitness hearing.
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