Case Citator › Pate v. Robinson

Pate v. Robinson

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
383 U.S. 375
Decided
Confirmed treatments
2
Flagged citations read
114 of 120
Citing cases (total)
3,036
Treatment dates
2011–2024
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Pate v. Robinson is limited: 114 of the 120 flagged citations were read; the text of the other 6 could not be retrieved, and the 2 confirmed limiting treatments are listed below. Perkins v. Hall rejected an expansive reading of Pate that would categorically exempt substantive incompetency claims from Georgia's habeas procedural-default rule.
More on how this was screened

Xengxai Yang v. United States declined to extend Pate's trial-stage nonwaiver principle to competency claims first raised on collateral review. The other reviewed opinions followed or applied Pate's competency-hearing rules, made case-specific determinations about whether a retrospective hearing remained feasible, reported adverse treatment of other precedents, or used nearby treatment language for unrelated issues.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

3,036 later cases cite Pate v. Robinson; 120 of those citations sat close to treatment language and were flagged for reading; 114 of them have been read, and the text of 6 citing opinions could not be retrieved, so those remain unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Pate v. Robinson?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Supreme Court of Georgia rejected an expansive reading of Pate's competency nonwaiver rule and held that substantive incompetency claims remain subject to Georgia's habeas procedural-default rule.

    Perkins v. Hall · Supreme Court of Georgia · filed

    Accordingly, several federal circuits have rejected the Eleventh Circuit’s “expansive reading of Pate,” finding that approach “untenable when applied to a case in which the State has raised the defense of procedural default, rather than waiver,” with respect to a substantive claim of incompetence to stand trial. ... We therefore hold that, notwithstanding the contrary position of some federal courts, substantive claims of incompetence to stand trial will continue to be subject to procedural default in Georgia.
    Read the full opinion on CourtListener →

  • The Seventh Circuit confined Pate's competency nonwaiver rule to original trial proceedings and held that it does not prevent procedural default of a competency claim first raised on collateral review.

    Xengxai Yang v. United States · Seventh Circuit · filed

    Yang argues that Pate’s recognition of a defendant’s inability to waive competency implies that procedural default cannot apply. In his view, it is contradictory to prohibit waiver but to permit procedural default. But the law can prohibit a defendant from waiving competency before a trial court, while still subjecting competency claims to default for failing to observe the proper procedures in a collateral attack.
    Read the full opinion on CourtListener →

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