Hatfield v. Ballard
2012 U.S. Dist. LEXIS 95182
| S.D.W. Va | 2012Background
- Hatfield killed Tracey Andrews and wounded others on May 8, 1988; underwent psychiatric treatment after the crime and was found severely depressed with suicide risk.
- Competency experts in WV assessed Hatfield; one opined not competent to stand trial or to be criminally responsible; another found Hatfield not competent at the time of the crimes but competent to stand trial.
- Hatfield pled guilty to first-degree murder and two counts of malicious wounding in 1989 after questions about his competency; trial court deemed him competent and accepted the plea over psychiatrists’ concerns.
- Hatfield I (1991 WV Sup. Ct.) vacated the pleas due to concerns about competency at plea; remanded for development of the record and possible reentry of pleas.
- Hatfield II (1999 WV Sup. Ct.) affirmed remand results but did not explicitly address a full evidentiary competency hearing; dissent argued no competency hearing had ever occurred.
- Hatfield III (2008 WV Sup. Ct.) held Hatfield could not rely on “law of the case” or invited error to excuse lack of a full hearing; later, state habeas relief proceedings led to further developments.
- Hatfield filed federal habeas petition under 28 U.S.C. § 2254 in 2009; magistrate recommended summary-judgment for Hatfield, court ultimately granted petition, set aside conviction, and ordered discharge unless WV retried Hatfield timely.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hatfield procedurally defaulted or exhausted state remedies. | Hatfield did raise due-process/competency issues in state courts. | West Virginia doctrines (law of the case, invited error) barred merits. | No procedural default; equitable exception applied; Habeas relief granted on merits. |
| Whether the state trials violated clearly established federal law by failing to hold a full competency hearing. | Hatfield was not afforded a constitutionally adequate competency hearing. | State argued remand proceedings complied with Hatfield I/II. | State failed to provide an adequate competency hearing; due process violated. |
| Whether the plea and remand proceedings violated Dusky-era standards for competency. | Initial and remand hearings were flawed; evidence and cross-examination were lacking. | WV courts relied on lay judgments and deference to experts. | Constitutional errors; relief warranted under AEDPA standards. |
| Whether retrospective competency determinations are permissible in Hatfield’s case. | If needed, retrospective evaluation could establish past incompetence. | Remand proceedings did not permit reliable retrospective assessment. | Court declines to definitively authorize retrospective competency eval; outlines potential future considerations. |
| Whether Hatfield is entitled to discharge or retrial in light of the errors. | Hatfield’s conviction must be set aside and he discharged unless retried. | State may retry Hatfield; improper competency determinations were reversible error. | Habeas petition granted; conviction set aside; discharge unless timely retrial. |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (1960) (defining standard for competency to stand trial)
- Pate v. Robinson, 383 U.S. 375 (1966) (due process requires competency inquiry when reasonable doubt exists)
- Drope v. Missouri, 420 U.S. 162 (1975) (duty to hold competency hearing when fitness is contested)
- Medina v. California, 505 U.S. 437 (1992) (competency evaluation requirement in plea/stand-trial contexts)
- Godinez v. Moran, 509 U.S. 389 (1993) (same standard for competency to plead guilty and to stand trial)
- Kemna v. Colorado, 534 U.S. 362 (2002) (exceptional cases where state ground is inadequate under absolute application of rule)
- Lee v. Kemna, 534 U.S. 362 (2002) (exorbitant application of a generally sound rule may render state ground inadequate)
- McNeill v. Polk, 476 F.3d 206 (2007) (exhaustion/procedural default framework in Fourth Circuit)
- Hatfield I, State v. Hatfield, 186 W.Va. 507, 413 S.E.2d 162 (1991) (1991) (WV Sup. Ct. remand for competency development; concern with pleas and competency)
- Hatfield II, State v. Hatfield, 206 W.Va. 125, 522 S.E.2d 416 (1999) (1999) (WV Sup. Ct. addressed remand developments; dissent urged lack of full hearing)
- Hatfield III, Hatfield v. Painter, 222 W.Va. 622, 671 S.E.2d 453 (2008) (2008) (law-of-the-case and invited-error analysis; waiver concerns)