Matthews v. State, 358 S.C. 456

Summary

The Supreme Court of South Carolina held that trial counsel was ineffective for failing to request a competency hearing before the petitioner entered guilty pleas. Based on evidence of intellectual disabilities and severe brain damage, the court vacated the guilty plea and granted the petitioner a new trial.

Holdings

1. Trial counsel rendered ineffective assistance by failing to request a Blair hearing in light of substantial evidence that Matthews was incompetent to stand trial.
2. Due process prohibits the conviction of an incompetent defendant, and that protection cannot be waived by a guilty plea.

Questions Presented

1. Whether trial counsel was ineffective for failing to request a Blair hearing to determine Matthews's competency to stand trial before his guilty plea.
2. Whether Matthews proved that he was incompetent when he entered his guilty plea and that counsel's failure to request a competency hearing prejudiced the outcome.

Disposition

reversed_and_remanded