198 So. 3d 325
Miss. Ct. App.2015Background
- Brown was sentenced to life for murder of Shorelanda and 20 years for manslaughter of their unborn child in 1999.
- Brown pled guilty in 1999 without an on-the-record competency hearing; a psychologist later found him competent to stand trial.
- A court-ordered psychological exam was requested; Dr. Lott evaluated Brown and found present ability to confer with counsel and understanding of proceedings.
- Brown filed a fourth postconviction-relief motion in 2014 alleging lack of a competency hearing violated due process and asserting newly discovered evidence and lack of a factual basis for the plea.
- Sanders v. State (2009) held a competency hearing is required when a court orders a psychiatric evaluation, but the court held Sanders is not retroactive to Brown’s 1999 plea under Teague/Manning.
- The majority affirmed the PCR dismissal; the dissent would reverse and remand for a Rule 9.06 competency hearing and potential retrial or institutionalization.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sanders is retroactive to Brown's 1999 plea | Brown argues Sanders must apply and trigger a competency hearing. | Brown's retroactivity is governed by Teague/Manning; Sanders is not retroactive. | Sanders not retroactive to Brown's plea. |
| Whether lack of formal competency hearing violated due process | Fundamental right not to stand trial while incompetent was violated due to absence of a hearing. | No due-process violation; Brown was deemed competent and no objection raised. | No due-process violation established; plea valid. |
| Whether the newly discovered-evidence claim survives procedural bars | Evidence from later proceedings qualifies as newly discovered and could change outcome. | Evidence was not newly discovered or material; would not likely change result. | Dismissed; not newly discovered. |
| Whether there was a sufficient factual basis for the guilty plea | Argues insufficient factual basis for the plea. | Factual basis established by Brown’s admissions and evidence surrounding the crime. | Sufficient factual basis; plea valid. |
Key Cases Cited
- Sanders v. State, 9 So.3d 1132 (Miss. 2009) (mandates competency hearing when court orders psychiatric evaluation; retroactivity analyzed later)
- Teague v. Lane, 489 U.S. 288 (U.S. 1989) (new rules not retroactive on collateral review unless narrow exceptions apply)
- Schriro v. Summerlin, 542 U.S. 348 (U.S. 2004) (distinguishes substantive vs. procedural rules for retroactivity)
- Manning v. State, 929 So.2d 885 (Miss. 2006) (narrow retroactivity framework adopted by Mississippi Supreme Court)
- Goodin v. State, 102 So.3d 1102 (Miss. 2012) (retroactivity applied in PCR context relating to Sanders (counsel effectiveness context in Goodin))
- Smith v. State, 149 So.3d 1027 (Miss. 2014) (due-process competency considerations; reiterates Rule 9.06 requirements)
- Coleman v. State, 127 So.3d 161 (Miss. 2013) (Rule 9.06 compliance and the necessity of a competency hearing following court-ordered examination)
- Dusky v. United States, 362 U.S. 402 (1960) (definition of competency to stand trial)
- Pate v. Robinson, 383 U.S. 375 (1966) (competency determination rights and waivability concepts)