Mack West, Jr. v. Randy Grounds
708 F. App'x 476
9th Cir.2018Background
- Mack A. West, a California state prisoner, appealed the denial of his 28 U.S.C. § 2254 habeas petition contesting the trial court’s refusal to hold a fourth competency hearing after his mental health declined and he attempted suicide.
- West had been evaluated dozens of times over more than five years by at least four psychologists; many evaluators suspected malingering or symptom exaggeration to delay trial.
- Prior to the requested fourth hearing West made suicide attempts; the trial judge considered those attempts in deciding whether to convene another competency hearing.
- The question presented was whether the trial judge unreasonably failed to find a bona fide doubt about West’s competence and thus should have held another competency hearing under due process principles.
- The Ninth Circuit reviewed the state court’s decision under AEDPA standards, asking whether the state court’s decision was contrary to clearly established federal law or an unreasonable determination of the facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a fourth competency hearing was required after suicide attempts and deterioration | West: suicide attempts and mental decline created a bona fide doubt about competence requiring a hearing | State/Trial court: extensive prior evaluations showing suspected feigning meant no bona fide doubt warranted | Denied—no clearly unreasonable factual analysis; no bona fide doubt given full record |
| Whether suicide attempts alone trigger a competency hearing | West: recent suicide attempts indicate incompetence | State: suicide attempts are relevant but not dispositive; must be weighed with other evidence | Held: suicide attempts relevant but do not automatically require a hearing |
| Standard of review under AEDPA for competency-hearing determinations | West: state decision was unreasonable under AEDPA | State: trial court’s factfinding entitled to deference; reasonable evaluation of evidence | Held: state court’s determination was not an unreasonable application of federal law |
| Weight of prior psychiatric evaluations and possible malingering | West: prior evaluations do not foreclose consideration of new suicidal behavior | State: numerous evaluations documented likely feigning, supporting judge’s skepticism | Held: reasonable for trial judge to conclude feigning; prior evaluations supported denial of a new hearing |
Key Cases Cited
- Pate v. Robinson, 383 U.S. 375 (due process forbids trying an incompetent defendant)
- Dusky v. United States, 362 U.S. 402 (competency standard: factual and rational understanding and ability to consult with counsel)
- Drope v. Missouri, 420 U.S. 162 (trial judge must assess all evidence; no fixed quantum of proof for triggering hearing)
- Davis v. Woodford, 384 F.3d 628 (9th Cir.) (competency hearing required only when evidence raises a bona fide doubt)
- de Kaplany v. Enomoto, 540 F.2d 975 (9th Cir. en banc) (bona fide doubt defined from perspective of reasonable trial judge)
- Maxwell v. Roe, 606 F.3d 561 (9th Cir.) (suicide attempts relevant but not necessarily dispositive for competence)