Ricky Chase v. State of Mississippi
2015 Miss. LEXIS 194
| Miss. | 2015Background
- Ricky Chase, convicted of 1989 capital murder and sentenced to death, filed a post-conviction relief motion claiming intellectual disability under Atkins v. Virginia and state precedent; circuit court denied relief and this appeal follows.
- This Court previously authorized an Atkins-based evidentiary hearing and set diagnostic/practical procedures (Chase v. State) and recognized that IQ alone is not dispositive.
- At a 2010 evidentiary hearing, experts for Chase relied on 2010 AAIDD/2013 APA definitions and retrospective third‑party interviews to conclude Chase met intellectual‑disability criteria; the State’s expert concluded he did not.
- Key test results: historical WAIS-R (1989) FSIQ ~71; WAIS‑IV (2010) reported FSIQ adjusted to 71 (malingering tests did not indicate feigning).
- The circuit court credited the State expert (Dr. Macvaugh) over Chase’s experts (Drs. Reschly and O’Brien), found Chase failed to prove significant adaptive deficits by a preponderance, and denied a motion to reopen for additional testimony.
- The Mississippi Supreme Court affirmed, and expressly adopted the 2010 AAIDD and 2013 APA definitions as appropriate for Eighth Amendment intellectual‑disability determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Chase proved significantly subaverage intellectual functioning (IQ) | Chase: WAIS tests and historical scores (71) plus malingering tests show subaverage functioning (IQ ≤75) | State: Scores, testing conditions, and expert opinion show borderline intelligence, tests may understate capacity | Court: Chase proved subaverage functioning (court found IQ ~71) but later questioned validity when adaptive prong lacked support; overall affirmed denial on other grounds |
| Whether Chase proved significant adaptive‑functioning deficits | Chase: Third‑party interviews, school records, work history show deficits across conceptual, social, and practical domains | State: School performance, WRAT and memory testing, vocabulary and work records do not show deficits; expert testimony refutes deficits | Court: Trial court reasonably rejected Chase’s experts (methodological weaknesses, lack of normed interview data) and credited State expert; affirmed that Chase failed to prove adaptive deficits by preponderance |
| Admissibility/use of updated clinical definitions | Chase: Experts used 2010 AAIDD/2013 APA definitions; these reflect current clinical practice | State: Relied on earlier Atkins/Chase framework and clinical testing | Held: Court adopted 2010 AAIDD and 2013 APA definitions for use alongside Atkins/Chase standards in Mississippi courts |
| Whether trial court abused discretion by denying motion to reopen for additional third‑party testimony | Chase: Reopening needed so court could assess credibility of third‑party witnesses interviewed by Dr. Reschly | State: Trial court reasonably exercised discretion; additional testimony unlikely to change expert conclusions | Court: Denial of motion for new trial/reopening was not an abuse of discretion; affirmed |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (death penalty unconstitutional for intellectually disabled defendants)
- Hall v. Florida, 572 U.S. 701 (2014) (limits on states’ discretion in defining intellectual disability; IQ cutoffs cannot be applied mechanistically)
- Chase v. State, 873 So.2d 1013 (Miss. 2004) (Mississippi’s Atkins framework and procedural requirements for evaluating intellectual disability)
- Goodin v. State, 102 So.3d 1102 (Miss. 2012) (retrospective analysis and evidentiary standards for adaptive‑functioning assessments)
- Enmund v. Florida, 458 U.S. 782 (1982) (scope of capital liability for non‑triggermen)
- Tison v. Arizona, 481 U.S. 137 (1987) (capital liability when major participant displays reckless indifference to human life)