Cage v. State
2017 Ark. 277
| Ark. | 2017Background
- On Jan. 19, 2013, George Cage called dispatch saying he had shot his wife; officers arrested him. The wife (Mendi Bell) and her unborn fetus later died from stab wounds. Cage gave a statement admitting stabbing and later retrieving a gun and calling dispatch, saying he had killed his wife.
- The State charged Cage with capital murder (unborn child) and first-degree murder (wife). Cage moved for psychiatric evaluation claiming lack of capacity due to mental disease or defect.
- Dr. Mark Peacock initially diagnosed schizophrenia and found Cage unfit to proceed; the circuit court committed Cage to the state hospital for treatment. After treatment, Dr. Jason Beaman evaluated Cage and found him fit to proceed; Cage was discharged.
- Dr. Peacock later reevaluated (Feb. 2016) and concluded Cage was fit to proceed, finding refusal to participate was volitional and medication produced psychiatric stability. The circuit court held a competency hearing and found Cage competent to stand trial.
- At trial the defense presented Dr. Beaman (video deposition), who testified Cage did not have a severe mental disease or defect at the time of the offense; he diagnosed antisocial personality disorder and opined schizophrenia was treated. The jury convicted Cage of capital murder and first-degree murder and imposed two consecutive life terms (one without parole).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Cage) | Held |
|---|---|---|---|
| Competency to stand trial | Court should find Cage competent based on expert reports and examinations showing fitness after treatment | Cage argued he remained incompetent: counsel testified Cage could not assist, did not understand hearings, and Dr. Peacock had insufficient contact when diagnosing schizophrenia | Court held substantial evidence (Drs. Peacock and Beaman reports, observations at hearing) supported finding Cage competent to stand trial; affirmed |
| Jury instruction on mental disease or defect (AMI Crim. 2d 609 & 610) | State argued no evidence that Cage had a mental disease or defect at the time of the offense; defense experts testified treated state and no severe disease at offense | Cage argued the instructions should have been given because of evidence of schizophrenia and prior findings of mental illness that could bear on culpability | Court held no abuse of discretion in refusing instructions because no evidence showed Cage lacked capacity at time of offense; defense’s own expert negated the instruction |
| Right to bench trial waiver concerns | State: bench trial denial was within court’s discretion; no right to bench trial in capital case absent appropriate hearing | Cage argued judge’s remarks implied he doubted Cage’s competency to waive jury trial | Court held trial court’s denial proper; no error—no constitutional right to bench trial; note that Cage did not request full hearing referenced by judge |
| Preservation / review of other adverse rulings (Rule 4-3(i)) | State: record shows no prejudicial error affecting conviction | Cage: asserted various pretrial and trial rulings were adverse | Court reviewed record per Rule 4-3(i) and found no prejudicial error; affirmed |
Key Cases Cited
- Jacobs v. State, 294 Ark. 551, 744 S.W.2d 728 (Ark. 1988) (due-process bar to convicting legally incompetent defendant)
- Pate v. Robinson, 383 U.S. 375 (U.S. 1966) (constitutional requirement to determine competency before trial)
- Thessing v. State, 365 Ark. 384, 230 S.W.3d 526 (Ark. 2006) (defendant bears burden to prove incompetence)
- Haynes v. State, 346 Ark. 388, 58 S.W.3d 336 (Ark. 2001) (competency standard: factual and rational understanding and ability to consult with counsel)
- Baumgarner v. State, 316 Ark. 373, 872 S.W.2d 380 (Ark. 1994) (appellate review asks whether substantial evidence supports competency finding)
- Mauppin v. State, 314 Ark. 566, 865 S.W.2d 270 (Ark. 1993) (definition of substantial evidence standard)
- Carrier v. State, 278 Ark. 542, 647 S.W.2d 449 (Ark. 1983) (psychiatric report finding fitness can be substantial evidence for competency)
- Davis v. State, 293 Ark. 472, 739 S.W.2d 150 (Ark. 1987) (party entitled to instruction only if evidence supports it)
- Jones v. State, 336 Ark. 191, 984 S.W.2d 432 (Ark. 1999) (standard of review for jury-instruction rulings is abuse of discretion)
- Singer v. United States, 380 U.S. 24 (U.S. 1965) (no constitutional right to a bench trial)