More than competency was required for 17-year-old Heath Allen Wilkins to waive counsel and plead guilty to a murder charge. He may have been competent to stand trial, but the Court held that his waiver of representation and subsequent guilty plea was not made knowingly and voluntarily.

At age 16, Wilkins and three friends robbed a liquor store during which Wilkins killed an employee. A court ordered psychological evaluation determined Wilkins was competent to stand trial. A psychiatrist who also examined Wilkins without opining about his competency to stand trial, expressed doubt that Wilkins' emotional state would enable him to act in his own interest

Wilkins then decided to proceed pro se because he desired the death penalty. He subsequently pled guilty and then was sentenced to death. The conviction and sentence were subsequently affirmed by the Missouri Supreme Court on automatic review and by the state courts again when Wilkins sought post conviction relief.

In affirming the District Court's conditional grant of a writ of habeas corpus, the 8th Circuit set out the test to be met for a valid waiver of counsel and guilty plea.

The defendant must understand the nature of the charges, the possible lesser-included offenses, the range of penalties, possible defenses, mitigating circumstances and any other factors essential to an understanding of the situation.

This standard requires going beyond a simple finding of competency. Unless the Court, in addition to finding Defendant competent, was satisfied that he understood his options and his circumstances, it could not accept his waiver as being knowing and voluntary.