(CN) – A divided Supreme Court ruled Monday that an Alabama death-row inmate was denied his constitutional right to an independent mental health expert to help the defense team in his murder trial.
James Edmund McWilliams Jr. challenges his death sentence for robbing, raping and killing convenience store clerk Patricia Reynolds in Tuscaloosa, Ala., in 1984.
Months before he murdered Reynolds, McWilliams attended couple’s therapy with his pregnant wife and underwent psychological testing, which found that he is “extremely disturbed” and “has much internal anxiety.”
While three doctors nevertheless concluded he was competent to stand trial, his defense counsel portrayed McWilliams during the penalty phase of his trial as someone who grew up with significant psychological problems. McWilliams and his mother testified that he sustained head injuries as a child and had a history of blacking out and hallucinating.
An expert appointed by the trial judge reported his findings simultaneously to the court, the prosecution and the defense two days before McWilliams’ sentencing hearing.
The expert diagnosed McWilliams with organic personality syndrome, but defense counsel did not have a chance to discuss the findings with the expert or learn what the diagnosis meant for the purposes of mitigation.
Last year, McWilliams petitioned the U.S. Supreme Court for a writ of certiorari, arguing he was “precluded from meaningfully participating in the judicial sentencing hearing and did not receive a fair opportunity to rebut the state’s psychiatric experts.”
His case is nested inside the high court’s 1984 decision in Ake v. Oklahoma, which held that poor criminal defendants using a defense of insanity are entitled to an expert to help support their claim.
McWilliams was charged by Alabama just a month after Ake was decided. His appeals over the years have been unsuccessful, with the 11th Circuit affirming the lower courts’ denial of relief.
Five months after agreeing to take up the case, the Supreme Court reversed the 11th Circuit and ruled 5-4 Monday that McWilliams did not receive the assistance he was entitled to under Ake.
Justice Stephen Breyer, writing for the majority, said that Ake does not require just an examination, but also requires the state to provide the defense access to a competent psychiatrist who will also help in evaluation, preparation and presentation.
“We are willing to assume that Alabama met the examination portion of this requirement by providing for Dr. [John] Goff ’s examination of McWilliams. But what about the other three parts?” Breyer wrote. “The dissent emphasizes that Dr. Goff was never ordered to do any of these things by the trial court. But that is precisely the point. The relevant court order did not ask Dr. Goff or anyone else to provide the defense with help in evaluating, preparing, and presenting its case.” (Emphasis in original.)
McWilliams’ requests for additional assistance under Ake were rejected by the judge in his case, according to the ruling.
“Since Alabama’s provision of mental health assistance fell so dramatically short of what Ake requires, 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,’” Breyer said.
The Supreme Court said the 11th Circuit should determine on remand “whether access to the type of meaningful assistance in evaluating, preparing, and presenting the defense that Ake requires could have made a difference” in McWilliams’ trial.
Justices Anthony Kennedy, Ruth Bader Ginsburg, Sonio Sotomayor and Elena Kagan joined Breyer in the majority.
Justice Samuel Alito wrote the dissenting opinion, and was joined by Chief Justice John Roberts and Justices Clarence Thomas and Neil Gorsuch.
Alito said Ake “did not clearly establish that a defendant is entitled to an expert who is a member of the defense team.”
“In Ake, we held that a defendant must be provided ‘access to a competent psychiatrist’ in two circumstances: first, ‘when [the] defendant demonstrates to the trial judge that his sanity at the time of the offense is to be a significant factor at trial,’ and, second, at the sentencing phase of a capital trial, ‘when the State presents psychiatric evidence of the defendant’s future dangerousness,’” Alito wrote.
“The question that we agreed to review concerns the type of expert that must be provided. Did Ake clearly establish that a defendant in the two situations just noted must be provided with the services of an expert who functions solely as a dedicated member of the defense team as opposed to a neutral expert who examines the defendant, reports his or her conclusions to the court and the parties, and is available to assist and testify for both sides? Did Ake speak with such clarity that it ruled out ‘any possibility for fairminded disagreement’? The answer is ‘no.’ Ake provides no clear guidance one way or the other.”
McWilliams' attorney Stephen Bright said in a statement that Monday's decision "is about fairness."
"The adversarial process cannot function properly if the prosecution can retain mental health experts, but the defense is not even allowed to consult with an expert," Bright said. "A mental health expert who can assist in the evaluation, preparation, and presentation of the defense is indispensable in a case where the defendant’s mental health is a significant issue, as it was in this case."
He added, "The trial judge who sentenced McWilliams to death found no mitigating circumstances even though McWilliams had serious mental health issues. The judge could not have made that finding if McWilliams’s attorneys had a mental health expert to assist them in presenting the mitigating circumstances regarding mental health."
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