Companonio v. O'Brien, 2012 U.S. App. LEXIS 4553

Companioni appeals the district court's denial of habeas relief from a life sentence for 1987 Massachusetts first-degree murder.
Petition allege ineffective assistance of counsel for failing to pursue a mental illness defense; SJC held he was competent and that he instructed counsel to forego the defense.
May 19, 1986: Companioni joined Nohoya and Lopez; after intoxication and gunplay, he shot Nohoya and Lopez; Nohoya died; Companioni was convicted of first-degree murder and sentenced to life without parole.
Post-conviction motion for new trial based on mental-illness defense; evidentiary hearing conducted; Dr. Moore found no major mental disorder and competence to stand trial.
Defense asserted meetings about a mental-illness defense occurred; trial counsel testified he discussed it and consulted experts; Companioni and his brother disputed those meetings.
Pre-trial Bridgewater State Hospital transfers yielded diagnoses including paranoid schizophrenia, but experts consistently found competency to stand trial; SJC affirmed competence and ruling on the defense decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Companioni's trial competency correctly upheld?	Companioni argues incompetency pre-trial undermines waiver/participation.	State courts found him competent to stand trial and to assist counsel.	No error; competency supported by record.
Did counsel's failure to pursue a mental impairment defense amount to ineffective assistance?	Companioni claims counsel should have pursued mental-illness defense.	Counsel adequately investigated and acted on Companioni's instructions.	No prejudice; strategy aligned with Companioni's instructions and competency findings.
Was the district court's denial of an evidentiary hearing appropriate?	Habeas hearing needed to explore competency to waive the mental-illness defense.	District court properly denied; hearing would replicate state record and was unnecessary.	affirmed; no abuse of discretion.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective-assistance standard)
Harrington v. Richter, 131 S. Ct. 770 (U.S. 2011) (to prevail, defendant must show both deficient performance and prejudice)
Brown v. O'Brien, 666 F.3d 818 (1st Cir. 2012) (competency and ability to consult with counsel; factual deference)
Yeboah-Sefah v. Ficco, 556 F.3d 53 (1st Cir. 2009) (de novo review standard for habeas corpus)
Robidoux v. O'Brien, 643 F.3d 334 (1st Cir. 2011) (competency includes ability to assist counsel)
Godinez v. Moran, 509 U.S. 389 (U.S. 1993) (competency to stand trial includes ability to confer with counsel)
Dusky v. United States, 362 U.S. 402 (U.S. 1960) (standard for competency to stand trial)
Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (distinguishes competency to stand trial from capacity to defend)
Commonwealth v. Companonio, 833 N.E.2d 136 (Mass. 2005) (Mass. competency and waiver precedents; trial strategy deference)
Hill v. Commonwealth, 375 N.E.2d 1168 (Mass. 1978) (competency evaluation timing standard)
Teti v. Bender, 507 F.3d 50 (1st Cir. 2007) (when to grant evidentiary hearing in habeas corpus)
Brown v. O'Brien, 666 F.3d 818 (1st Cir. 2012) (competency and waiver; factual sufficiency standards)