Background
On July 26, 2023, the State charged Trent W. DeShane with attempt first-degree murder, aggravated battery with a firearm, and reckless discharge of a firearm. In August 2023, a bona fide doubt regarding defendant’s fitness was raised, triggering an evaluation by Dr. Chad Brownfield. Dr. Brownfield concluded defendant met legal criteria for fitness to stand trial.
At a November 6, 2023 hearing, defense counsel stipulated to Dr. Brownfield’s qualifications but indicated defendant objected to the conclusions. Defendant requested a second opinion, and the court appointed Dr. Joel Eckert for an independent evaluation. On March 4, 2024, Dr. Eckert also concluded defendant was fit.
At the March 2024 fitness hearing, both the State and defense counsel stipulated to Dr. Eckert’s qualifications and conclusions without presenting any evidence or testimony. The trial court then ruled defendant fit based solely on these stipulations, with no independent review of either expert report. Defendant was subsequently convicted of aggravated battery with a firearm and reckless discharge of a firearm in April 2025 and sentenced to 12 years in prison.
The Court’s Holding
The appellate court held that the trial court committed clear and obvious error by conducting an entirely conclusory fitness hearing based solely on parties’ stipulations to expert reports without conducting any independent judicial inquiry into fitness. The Due Process Clause of the Fourteenth Amendment prohibits prosecution of defendants who are not fit to stand trial, and this constitutional protection cannot be satisfied by passive acceptance of expert opinions.
The court distinguished between two types of stipulations: parties may stipulate to the fact of fitness (thereby accepting the expert’s conclusion as true), or they may stipulate to the content of expert testimony that would have been presented. Only in the latter circumstance may a court make an independent determination, as the ultimate decision must rest with the court, not the experts. A trial court must be active, not passive, and must do more than serve as a rubber stamp for expert opinions.
The trial court here failed to exercise judicial discretion and independent judgment by relying exclusively on the parties’ stipulations without reviewing the reports, analyzing the experts’ bases for their opinions, or making any independent inquiry whatsoever. This violated defendant’s due process rights.
Key Takeaways
- Trial courts cannot base fitness determinations solely on parties’ stipulations to expert reports; an independent judicial inquiry is constitutionally required
- Courts must actively evaluate and analyze the factual basis for expert opinions on fitness, not merely accept expert conclusions
- The distinction between stipulating to facts versus stipulating to testimony content preserves a court’s obligation to exercise independent judicial judgment
- Fitness determinations implicate constitutional due process rights that cannot be waived or bypassed through procedural stipulations
Why It Matters
This decision reinforces that the constitutional prohibition against prosecuting unfit defendants creates an affirmative judicial duty that cannot be satisfied through default or stipulation. Trial courts must actively oversee fitness determinations rather than passively accepting expert opinions, even when both parties agree. The ruling prevents trial courts from becoming mere formalities in proceedings with profound constitutional implications, ensuring that judicial discretion and independent judgment are genuinely exercised.
The case has practical significance for criminal defense and prosecution practice: fitness hearings cannot be streamlined through stipulations without risking reversal, even when both parties consent. Courts must independently review expert reports and make factual findings, potentially extending proceedings but protecting due process. The appellate court remanded for a retrospective fitness hearing, reserving all other appellate issues (structural defects, hearsay, ineffective assistance claims) for defendant to raise after the fitness determination is properly conducted.