Goodin v. State, 2012 Miss. LEXIS 616

Goodin appeals the Newton County Circuit Court's denial of post-conviction relief.
The circuit court held Goodin was not mentally retarded and denied ineffective-assistance claims on mental illness and competency.
The Court reverses and renders on mental retardation and remands for resentencing on capital murder; the death sentence is vacated.
Whitfield-era evaluations and multiple experts over decades culminated in a contested retroactive retardation determination.
The court remanded for resentencing after finding Goodin mentally retarded under Atkins v. Virginia and Chase v. State, despite incarceration affecting adaptive-function testing.
The proceedings included a bifurcated focus on sentencing mitigation and trial-competency issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Goodin is mentally retarded under Atkins/Chase.	Goodin (Goodin) met subaverage intellect, adaptive deficits, onset before 18.	State/Trial court held no mental retardation due to adaptive-function testing and malingering concerns.	Yes; Goodin is mentally retarded under Atkins/Chase.
Whether trial counsel was ineffective for mental-illness considerations at sentencing.	Goodin's counsel failed to pursue mental-illness mitigation.	Counsel acted within reasonable strategic bounds given evidence and standards.	Merits not reached due to ruling on retardation? (Court addresses, but primarily reversed on retardation; rationale acknowledges ineffective-assistance in other context.)
Whether trial counsel was ineffective for competency at conviction.	Counsel failed to investigate/seek competency hearings or obtain records.	Counsel relied on psychiatric reports deeming Goodin competent.	Yes; deficient performance found and prejudice shown, but conviction not reinstated due to remand on retardation.
Whether Chase v. State's requirements were misapplied to expert testimony at the hearing.	Threshold expert testimony was not properly required to proceed before other evidence.	Chase's threshold requirement should be applied as described.	Chase threshold correctly applied; circuit court erred in sequencing expert testimony.

Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (execution of mentally retarded is unconstitutional)
Chase v. State, 873 So.2d 1027 (Miss. 2004) (defines retardation standards and malingering considerations)
Doss v. State, 19 So.3d 690 (Miss. 2009) (recognizes retrospective evaluation and adaptive functioning concerns)
Thorson v. State, 76 So.3d 667 (Miss. 2011) (retrospective analysis for Atkins onset before 18)
Sanders v. State, 9 So.3d 1132 (Miss. 2009) (necessity of competency hearing when doubt arises)