United States v. Lightly
United States Court of Appeals for the Fourth Circuit
677 F.2d 1027 (1982)
Randy Lightly (defendant) and fellow inmate Clifton McDuffie were investigated for stabbing another inmate, McKinley; McDuffie was found criminally insane and incompetent to stand trial and was not indicted, while Lightly was. At Lightly's trial, several witnesses said Lightly and McDuffie together attacked McKinley, but Lightly and three corroborating inmates testified McDuffie alone did the stabbing and cut Lightly's hand when Lightly tried to intervene. Lightly sought to call McDuffie, whose treating physician testified McDuffie had sufficient memory, understood the oath, and could describe what he saw; the trial court nonetheless disqualified McDuffie as incompetent to testify based solely on his insanity finding and hallucinations, without hearing his proffered testimony in camera, and Lightly was convicted.
Whether a person deemed criminally insane and incompetent to stand trial may be disqualified as incompetent to testify under Federal Rule of Evidence 601.