Jonathan Huey Lawrence v. Secretary Florida Department of Corrections
2012 U.S. App. LEXIS 22387
| 11th Cir. | 2012Background
- This is a capital case addressing whether defense counsel were ineffective for not seeking a competency hearing at the penalty phase and whether Lawrence was actually incompetent when he pled guilty to murder.
- Lawrence pled guilty in 2000 after trial counsel stated the decision was his and the court conducted a lengthy colloquy confirming understanding and voluntariness, while noting Lawrence’s mental deficiencies.
- Penalty phase followed Guilty Plea; two incidents involving alleged hallucinations/flashbacks occurred, prompting debates about Lawrence’s competence during the penalty phase.
- State postconviction proceedings in 2005-2007 presented conflicting expert opinions on Lawrence’s competency, including several court-appointed and defense experts.
- Florida Supreme Court denied relief on Strickland claims, holding counsel’s decision not to request a competency hearing was reasonable and that Lawrence failed to show prejudice.
- AEDPA governs federal habeas review, with highly deferential review of state court determinations, including competency determinations and Strickland claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffectiveness of failure to seek competency hearing | Lawrence argues counsels’ failure to request a competency hearing during penalty phase was deficient. | Killam/Stitt contended no competency problem; decisions were reasonable professional judgments. | No reversible Strickland deficiency; reasonable professional judgment. |
| Actual competency at guilty plea/penalty phase (Dusky claim) | Lawrence contends he was not competent to plead guilty or stand trial due to schizophrenia. | District court and Florida courts disputed a substantial doubt; evidence did not show incompetence. | No clear error; district court’s competency finding upheld; no due process violation. |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (1960) (tests for competency to stand trial)
- Strickland v. Washington, 466 U.S. 668 (1984) (deficient performance and prejudice standard)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (doubly deferential AEDPA/Strickland review)
- Renico v. Lett, 130 S. Ct. 1855 (2010) (deference to state court factual determinations)
- Wright v. Sec’y, Dep’t of Corr., 278 F.3d 1245 (2002) (substantive competency claims not procedurally defaulted)