Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
Smith's Criminal Case Compendium
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This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.
Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.
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In a per curiam decision in this capital murder case decided under the Antiterrorism and Effective Death Penalty Act of 1996, the Court held that the state court did not unreasonably apply the law when it determined that the defendant was competent to be executed. The defendant was sentenced to death in an Alabama court. As his execution neared, the defendant petitioned the trial court for a suspension of his death sentence, arguing that due to several recent strokes, he had become incompetent to be executed. At a hearing on the matter, a court appointed psychologist noted the defendant’s significant post-stroke decline but testified that he understood the posture of his case and that the State was seeking retribution against him for his criminal act. A defense psychologist testified that the defendant’s strokes rendered him unable to remember numerous events that had occurred in the past. However, he found that the defendant was able to understand the nature of the pending proceeding, what he was tried for, that he was in prison because of murder, that Alabama was seeking retribution for that crime, and the sentence, specifically the meaning of a death sentence. The defense witness also opined that the defendant does not understand the act he is being punished for because he cannot recall the sequence of events from the offense through the trial and believes that he “never went around killing folks.” After the trial court denied the defendant’s petition, the defendant pursued federal habeas proceedings. The federal district court denied the defendant’s petition and the Eleventh Circuit reversed. That court found that because the defendant has no memory of his capital offense it inescapably follows that he does not rationally understand the connection between his crime and his execution. On that basis, the federal appellate court held that the trial court’s conclusion that the defendant is competent to be executed was plainly unreasonable. The Court disagreed. Reviewing its prior case law, the Court concluded that those decisions did not clearly establish that a prisoner is incompetent to be executed because of a failure to remember his commission of the crime, as distinct from the failure to rationally comprehend the concepts of crime and punishment as applied in his case. Thus, the state court did not unreasonably apply Supreme Court law when it determined that the defendant was competent to be executed because, notwithstanding his memory loss, he recognizes that he will be put to death as punishment for the murder he was found to have committed.
In this Scotland County case, defendant appealed his convictions for attempted first-degree murder, assault with a deadly weapon with intent to kill inflicting serious injury, assault with a firearm on an officer, and carrying a concealed gun, arguing abuse of discretion in finding him competent to stand trial. The Court of Appeals disagreed, finding no error.
In May of 2018, defendant walked up to a crime scene and passed under the police tape into the secured area. Two officers on the scene moved to arrest defendant, and in the ensuing confrontation, defendant drew his firearm and shot at one of the officers. Defendant attempted to flee but was struck by shots from one of the officers. At the hospital, defendant was diagnosed with a traumatic brain injury. Before trial, defendant’s counsel filed a motion for capacity hearing due to his alleged memory loss from the brain injury. The trial court held a competency hearing, where a doctor provided by the defense testified that defendant could not remember the days leading up to the confrontation with police or the events of the day in question, but that defendant had a “rational understanding” of the legal proceedings against him. Slip Op. at 3. The trial court ruled defendant was competent to stand trial, and he was subsequently convicted.
Taking up defendant’s appeal, the Court of Appeals noted that “our Supreme Court has explained that even when a defendant’s ability to participate in his defense is limited by amnesia, it does not per se render him incapable of standing trial.” Id. at 6. Although defendant argued his memory loss made him unable to participate in his defense, the court disagreed, explaining “he was able to understand the nature and object of the proceedings against him and able to comprehend his own situation in reference to the proceedings.” Id. The court found no abuse of discretion by the trial court when weighing the testimony and concluding that defendant was competent to stand trial.
The defendant was competent to stand trial and to represent himself. As to competency to stand trial, the defendant had several competency evaluations and hearings; the court rejected the defendant’s argument that a report of the one doctor who opined that he was incompetent was determinative of the issue, noting that numerous other doctors opined that he was malingering. The court also rejected the defendant’s argument that even after several competency hearings, the trial court erred by failing to hold another competency hearing when the defendant disrupted the courtroom, noting in part that four doctors had opined that the defendant’s generally disruptive behavior was volitional. The court also rejected the defendant’s argument that even if he was competent to stand trial, the trial court erred by allowing him to proceed pro se. The court found Indiana v. Edwards inapplicable because here--and unlike in Edwards--the trial court granted the defendant’s request to proceed pro se. Also, the defendant did not challenge the validity of the waiver of counsel colloquy.