Supreme Court Vacates Death Row Sentence in McWilliams v Dunn
In McWilliams v Dunn, 582 U. S. ____ (2017), the U.S. Supreme Court overturned a death penalty sentence imposed more than 30 years ago. By a vote of 5-4, the majority held that Alabama failed to provide access to the kind of expert assistance from a mental health expert that the U.S. Constitution requires.
Legal Background in McWilliams v Dunn
In Ake v. Oklahoma, 470 U. S. 68 (1985), the Supreme Court established that when an indigent “defendant demonstrates . . . that his sanity at the time of the offense is to be a significant fact at trial, the State must” provide the defendant with “access to a competent psychiatrist who will conduct an appropriate examination and assist in evaluation, preparation, and presentation of the defense.”
As explained by the Court, “when the State has made the defendant’s mental condition relevant to his criminal culpability and to the punishment he might suffer, the assistance of a psychiatrist may well be crucial to the defendant’s ability to marshal his defense.” The Court further highlighted that a psychiatrist may also “gather facts,” “analyze the information gathered and from it draw plausible conclusions,” and “know the probative questions to ask of the opposing party’s psychiatrists and how to interpret their answers.”
Facts of McWilliams v Dunn
More than three decades ago, James Edmond McWilliams, Jr. was charged with rape and capital murder. Finding him indigent, the trial court appointed counsel, who requested a psychiatric evaluation of McWilliams. The State convened a commission, which concluded that McWilliams was competent to stand trial and had not been suffering from mental illness at the time of the alleged offense.
McWilliams was convicted of capital murder by an Alabama jury. While the parties awaited McWilliams’ judicial sentencing hearing, his counsel asked for neurological and neuropsychological testing of McWilliams. Dr. Goff performed an examination and filed a report two days before the judicial sentencing hearing. He concluded that McWilliams was likely exaggerating his symptoms but nonetheless appeared to have some genuine neuropsychological problems. Just before the hearing, counsel also received updated records from the commission’s evaluation and previously subpoenaed mental health records from the Alabama Department of Corrections. At the hearing, defense counsel requested a continuance in order to evaluate all the new material and asked for the assistance of someone with expertise in psychological matters to review the findings.
The trial court denied defense counsel’s requests, and McWilliams was sentenced to death. He challenged his sentence on appeal, arguing that the State denied him the right to meaningful expert assistance guaranteed by Ake. However, the Alabama courts refused to grant relief.
Majority Decision in McWilliams v Dunn
The majority held that “the Alabama courts’ determination that McWilliams received all the assistance to which Ake entitled him was contrary to, or an unreasonable application of, clearly established federal law.” Justice Stephen Breyer wrote for the majority, which included Justices Kennedy, Ruth Bader Ginsburg, Sonia Sotomayor, and Elena Kagan.
As noted by the Court, inmates seeking habeas corpus relief in federal court must demonstrate that the state court’s decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” Here, the majority concluded that McWilliams satisfied the high standard.
“Since Alabama’s provision of mental-health assistance fell so dramatically short of what Ake requires,” Justice Breyer wrote, “we must conclude that the Alabama court decision affirming McWilliams’s conviction and sentence was ‘contrary to, or involved an unreasonable application of, clearly established Federal law.’”
In reaching its decision, the majority rejected Alabama’s claim that the State was relieved of its Ake obligations because McWilliams received brief assistance from a volunteer psychologist at the University of Alabama. “Neither Dr. Goff nor any other expert helped the defense evaluate Goff’s report or McWilliams’ extensive medical records and translate these data into a legal strategy,” Justice Breyer noted. “Neither Dr. Goff nor any other expert helped the defense prepare direct or cross-examination of any witnesses, or testified at the judicial sentencing hearing himself.”
The majority also emphasized that McWilliams did not get all the mental health assistance that he requested. “Rather, he asked for additional help at the judicial sentencing hearing, but was rebuffed,” Justice Breyer stated.
In its narrow decision, the majority avoided the larger constitutional issue involving whether Ake meant that indigent defendants have the right to have meaningful assistance and participation from their own expert mental health witnesses. “This Court does not have to decide whether Ake requires a State to provide an indigent defendant with a qualified mental health expert retained specifically for the defense team,” Justice Breyer wrote. “That is because Alabama did not meet even Ake’s most basic requirements in this case. Ake requires more than just an examination.”
On remand, the majority directed the Eleventh Circuit to determine whether the Alabama courts’ error had the “substantial and injurious effect or influence” required to warrant a grant of habeas relief under Davis v. Ayala, specifically considering whether access to the type of meaningful assistance in evaluating, preparing, and presenting the defense that Ake requires could have made a difference.
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