## Facts

- An inmate at Lorton Reformatory, Randy Lightly, was prosecuted for a stabbing of inmate Terrance McKinley in McKinley’s cell.
- The government alleged Lightly and another inmate, Clifton McDuffie, jointly attacked McKinley with scissors, and that Lightly’s serious hand wound occurred during the assault.
- Lightly contended McDuffie alone attacked McKinley, and Lightly intervened to stop McDuffie and was injured while attempting to disarm him; three inmate witnesses corroborated Lightly’s account.
- A court-appointed psychiatrist concluded McDuffie was criminally insane at the time of the incident and incompetent to stand trial, and McDuffie was not indicted.
- The psychiatrist also opined McDuffie could testify because he understood the oath, could communicate what he observed, and had sufficient memory of the events.
- At trial, Lightly sought to call McDuffie as a defense witness.
- The district court ruled McDuffie incompetent to testify based largely on his mental illness and reports of hallucinations, without conducting an in camera voir dire or direct examination of McDuffie as a proposed witness.
- Lightly was convicted of assault with intent to commit murder and sentenced to a consecutive ten-year term.

## Issues

1. Whether the district court violated Federal Rule of Evidence 601 by disqualifying a defense witness as incompetent to testify based on insanity at the time of the offense and incompetence to stand trial.
2. Whether excluding the witness without an individualized competency examination improperly prevented the jury from hearing potentially exculpatory testimony central to the defense.

## Decision

- The Fourth Circuit reversed the conviction and remanded for a new trial.
- The court held the district court erred by disqualifying McDuffie without an adequate, witness-specific inquiry into testimonial competence.
- The court concluded the exclusion was not harmless because McDuffie’s testimony was highly material to Lightly’s defense and could corroborate the defense account of the stabbing.

## Legal Principles

- Federal Rule of Evidence 601 establishes a presumption that every person is competent to be a witness unless the rules provide otherwise.
- Mental illness, insanity, or incompetence to stand trial does not automatically render a person incompetent to testify; such conditions generally affect credibility and weight, not admissibility.
- Testimonial competence turns on whether the witness has personal knowledge, can recall events, can communicate them, and understands the obligation to testify truthfully.
- Competence to stand trial addresses the ability to understand proceedings and assist counsel; it is distinct from competence to testify.
- When competency is disputed, the trial court should conduct an individualized examination (often via voir dire outside the jury’s presence) rather than disqualify a witness solely from psychiatric reports and argument.

## Conclusion

The Fourth Circuit ordered a new trial because the district court improperly excluded a key defense witness under an overbroad view of incompetence, contrary to Rule 601’s presumption of competency and without a direct examination of the witness’s ability to perceive, remember, communicate, and understand the duty of truthfulness.


United States v. Lightly, 677 F.2d 1027 (4th Cir. 1982)