Robidoux v. O'BRIEN
2011 U.S. App. LEXIS 13140
| 1st Cir. | 2011Background
- Robidoux was convicted in Massachusetts state court of first-degree murder and is serving a life sentence.
- He challenged the denial of federal habeas relief alleging ineffective assistance of trial counsel, O'Boy.
- Robidoux belonged to a religious sect that distrusted medicine; his child died after nutritional restrictions aligned with sect beliefs.
- At trial, O'Boy argued starvation was not proven; Robidoux testified and admitted some responsibility but denied intent to harm.
- Robidoux filed post-trial motions; affidavits alleged undue influence and ineffective representation; the state court denied relief and the SJC affirmed.
- The federal district court denied habeas relief but granted a certificate on competency-related claims; the First Circuit reviews under Strickland.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel's failure to seek a competency hearing was deficient | Robidoux argues O'Boy should have sought competency evaluation | O'Brien contends competency was not lacking and no prejudice shown | No deficient performance or prejudice; SJC reasonable on competency finding. |
| Whether insanity as a defense should have been pursued | Robidoux contends insanity defense was viable given beliefs | O'Brien reasonably declined due to lack of diagnosed illness and Robidoux's wishes | Insanity defense not warranted; defense unlikely to succeed. |
| Whether diminished capacity should have been argued to negate intent | Robidoux asserts diminished capacity could negate intent | O'Brien's strategy did not err; evidence suggested intent despite beliefs | No reasonable probability of acquittal from diminished capacity theory. |
| Whether lack of an evidentiary hearing affects review of state fact findings | Robidoux argues lack of hearing undermines deference | State finding supported by trial record and judge's observations | State findings were reasonable under 28 U.S.C. § 2254(d)(2); no error in deference. |
| Whether any other trial strategy changes could have altered the outcome | Robidoux contends alternative tactics would yield different result | Counsel's strategy was reasonable given evidence and constraints | No reasonable probability of different outcome; no deficient strategy established. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance requires deficient performance and prejudice)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (competency involves understanding proceedings and ability to cooperate with counsel)
- Commonwealth v. Simpson, 428 Mass. 646, 704 N.E.2d 1131 (Mass. 1999) (Mass. standards for competency and ability to participate in trial)
- Commonwealth v. Mercado, 452 Mass. 662, 896 N.E.2d 1262 (Mass. 2008) (insanity/diminished capacity considerations in Massachusetts)
- Gould v. Gould, 380 Mass. 672, 405 N.E.2d 927 (Mass. 1980) (delusions and intent considerations in extreme atrocity cases)
- Wilson v. Gaetz, 608 F.3d 347 (7th Cir. 2010) (discusses deific decree/insanity defenses in extreme cases)
- United States v. James, 328 F.3d 953 (7th Cir. 2003) (example of non-insanity but nonstandard beliefs not implying mental instability)
- United States v. Landers, 564 F.3d 1217 (10th Cir. 2009) (insanity/competency considerations in jury deliberations)
- United States v. Drachenberg, 623 F.3d 122 (2d Cir. 2010) (illustrates related standards in competency arguments)