Humphrey, Warden v. Walker
294 Ga. 855
| Ga. | 2014Background
- Walker was convicted of murder and related crimes in 2002; death sentence imposed for murder, other terms for related crimes.
- On direct appeal, convictions and sentences were affirmed.
- In 2009, Walker obtained habeas relief; the habeas court vacated convictions and sentences after finding due process and ineffective assistance claims, including incompetence to stand trial.
- Habeas court concluded that trial counsel failed to adequately investigate Walker’s mental health, and that a competent psychiatric evaluation would have shown he was not competent to stand trial.
- Record showed extensive evidence of Walker’s mental illness from family, church associates, and lay witnesses, and Dr. Meck opined Walker was not competent to stand trial based on available information.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Walker denied due process by being tried while incompetent? | Walker | Warden | Yes; incompetence found at trial. |
| Did trial counsel render ineffective assistance by failing to pursue mental health evaluation? | Walker | Warden | Yes; ineffective assistance shown, causing prejudice. |
| Did cause-and-prejudice overcome procedural default to consider incompetence claim in habeas? | Walker | Warden | Yes; cause and prejudice established, overcoming default. |
Key Cases Cited
- Pate v. Robinson, 383 U.S. 375 (1966) (due process forbids conviction of the incompetent)
- Norris v. State, 250 Ga. 38 (1982) (competence standards for trial)
- Godinez v. Moran, 509 U.S. 389 (1993) (standard for competence to stand trial)
- Sims v. State, 279 Ga. 389 (2005) (trial court must assess competence; deferential review in habeas)
- Strickland v. Washington, 466 U.S. 668 (1984) (ineffective assistance standard; deficient performance and prejudice)
- Kimmelman v. Morrison, 477 U.S. 365 (1986) (framework for evaluating counsel performance in death-penalty cases)
- Harrington v. Richter, 562 U.S. 86 (2011) (heavy burden to prove unreasonable conduct and prejudice; deference to habeas findings)
- Perkins v. Hall, 288 Ga. 810 (2011) (cause-and-prejudice standard to overcome procedural default)
- Sims v. State, 279 Ga. 389 (2005) (competence standard and rights to counsel)