Paul Dennis Reid, Jr. v. State of Tennessee
396 S.W.3d 478
Tenn.2013Background
- Prisoner Paul Dennis Reid, Jr. faces seven death sentences for three murder cases; three trials occurred in 1999, 2000, and 200? involving Captain D’s, McDonald’s, and Baskin-Robbins killings.
- Sister Linda Martiniano filed “next friend” petitions seeking to declare Reid incompetent to pursue post-conviction relief; petitions were not signed/verified by Reid.
- Trial courts (Davidson County 2007; Montgomery County 2008) denied incompetency findings; courts applied a civil standard (Groves/Nix framework) to assess capacity.
- Court of Criminal Appeals affirmed; Tennessee Supreme Court granted Rule 11 appeal under Tenn. R. App. P. 11.
- Court held a single competency standard should apply to all post-conviction phases and must use Tenn. Sup. Ct. R. 28, § 11(B) with Groves/Nix framework.
- Court affirmed lower courts’ decisions, denying next-friend relief and holding future proceedings under Rule 28, § 11.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What standard governs prisoner competency in post-conviction matters? | Reid | State | Rule 28, §11 governs all phases and is aligned with groves-based decision-making standard. |
| Did the trial courts apply the correct standard in evaluating Reid’s competency? | Reid | State | Yes; courts correctly used Nix/Groves framework (civil competency) and applied clear-and-convincing burden. |
| Is the record clear and convincing that Reid lacked capacity to pursue relief? | Martiniano/Defender | State | No; record shows substantial credibility to multiple experts and no clear-contradictory finding of incompetence. |
| Whether a next-friend petition can proceed where competency is contested. | Martiniano/Defender | State | Denied; no prima facie showing of incompetence met; next-friend petitions dismissed. |
Key Cases Cited
- State v. Nix, 40 S.W.3d 459 (Tenn. 2001) (civil competency standard for tolling and post-conviction decisions; two-prong test.)
- In re Conservatorship of Groves, 109 S.W.3d 317 (Tenn. Ct. App. 2003) (capacity is task-specific; autonomy; decision-making capacity assessed case-by-case.)
- Reid v. State, 197 S.W.3d 694 (Tenn. 2006) (established Nix-based competency framework for next-of-kin petitions.)
- Holton v. State, 201 S.W.3d 626 (Tenn. 2006) (requirements for next friend; two threshold showings.)
- Rees v. Peyton, 384 U.S. 312 (1966) (federal standard for withdrawal of habeas petitions; informs Tennessee rule.)