Gray Maria v. William Muniz
704 F. App'x 641
| 9th Cir. | 2017Background
- Petitioner Gray Maria, who suffers from serious mental illness and experienced command hallucinations urging him to kill, was convicted of first-degree murder and assault after killing his quadriplegic cousin and stabbing a stranger.
- Maria pleaded not guilty by reason of insanity; the trial was bifurcated into a guilt phase and a sanity phase under California law.
- Defense counsel introduced no mental-illness evidence during the guilt phase; the jury found Maria guilty. In the sanity phase, experts for both sides agreed Maria understood the nature of his acts but disputed whether he knew they were wrong; the jury found him sane.
- Maria pursued state habeas relief alleging ineffective assistance of counsel; state courts summarily denied relief. He then sought federal habeas relief under 28 U.S.C. § 2254; the district court denied relief and the Ninth Circuit affirmed.
- The majority assumed counsel’s performance might be deficient under Strickland but held the state courts’ conclusions that Maria suffered no prejudice were not unreasonable under AEDPA deference; it also upheld the sufficiency of the evidence for the sanity verdict.
- Judge Murguia dissented in part, arguing counsel’s failure to present expert testimony in the guilt phase was deficient and prejudicial because undisputed command hallucinations could have negated premeditation and deliberation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance at guilt phase (failure to present mental-illness experts) | Maria: counsel’s failure to present expert testimony on command hallucinations deprived him of a viable path to negate premeditation/deliberation, causing prejudice. | State: counsel later secured competency hearing and reinstated insanity plea; circumstantial evidence (planning, concealment of knife, deliberation) meant omitted evidence would not likely change verdict. | Majority: assumed deficiency but affirmed no prejudicial effect under Strickland/AEDPA. Dissent: counsel deficient and prejudice established. |
| Failure to obtain prior psychiatric records | Maria: missing records could have supported insanity/guilt-phase defenses. | State: Maria failed to show what additional, material information the records would have provided. | Majority: no prejudice shown; state court decision not unreasonable. |
| Sanity-phase trial management (order of expert testimony, opening statement) | Maria: trial tactics and testimony order impeded his sanity defense. | State: counsel effectively highlighted expert discrepancies and urged insanity; alternative tactics unlikely to change outcome. | Majority: no prejudice; verdict stands. |
| Sufficiency of evidence for sanity verdict | Maria: insufficient evidence to show he knew his actions were wrong given hallucinations and disputed intent. | State: jury could reasonably credit prosecution expert, interrogation transcript, and conduct to find Maria knew his acts were wrong. | Majority: under double-deference standard, state-court decision affirming sanity verdict was not objectively unreasonable; claim fails. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (standard for ineffective assistance of counsel)
- Coleman v. Johnson, 566 U.S. 650 (deference in sufficiency-of-the-evidence review)
- Cavazos v. Smith, 565 U.S. 1 (objective unreasonableness standard on habeas)
- Wiggins v. Smith, 539 U.S. 510 (reasonable-probability prejudice standard)
- Wood v. Ryan, 693 F.3d 1104 (ineffective-assistance analysis cited by dissent)
- Lambright v. Schriro, 490 F.3d 1103 (reasonable-probability definition)
- Duncan v. Ornoski, 528 F.3d 1222 (prejudice showing where expert testimony could create reasonable doubt)
- People v. Stress, 205 Cal.App.3d 1259 (command hallucinations can negate planning/deliberation)
- People v. Bobo, 229 Cal.App.3d 1417 (delusional system can be compatible with premeditation/deliberation)
- People v. Duckett, 162 Cal.App.3d 1115 (guilt-phase use of mental-illness evidence to negate premeditation)
- People v. Mills, 55 Cal.4th 663 (distinguishing purposes of guilt and sanity phases)
- People v. McGehee, 246 Cal.App.4th 1190 (mental illness evidence and specific intent)
- People v. Anderson, 70 Cal.2d 15 (factors for premeditation/deliberation)