Staley, Steven Kenneth
420 S.W.3d 785
Tex. Crim. App.2013Background
- Steven Staley, sentenced to death in 1991, was found incompetent to be executed in 2006 after psychiatric evaluations showing severe, chronic psychosis and repeated medication refusal. The trial court withdrew the execution date.
- The trial court nevertheless entered an order in 2006 authorizing involuntary administration of antipsychotic medication (Haldol), citing both medical benefit and the State’s interest in enforcing the sentence; that administrative/disciplinary process was not used.
- The involuntary-medication order was unsuccessfully challenged as interlocutory in 2007. The statutory competency scheme was amended in 2007 to permit appeals of competency findings to the Court of Criminal Appeals.
- Periodic reexaminations were conducted; by 2012 two experts testified Staley was competent to be executed while on medication but would likely decompensate if taken off it.
- The trial court found Staley competent to be executed based solely on his being medicated and set an execution date. The Court of Criminal Appeals granted review and stayed the execution.
- The Court held the trial court lacked statutory authority under Article 46.05 to order involuntary medication to restore competency, vacated the medication order and the competency finding, and remanded for periodic re-evaluation.
Issues
| Issue | Plaintiff's Argument (Staley) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Court of Criminal Appeals has jurisdiction to review the 2012 competency determination and the prior involuntary-medication order | Current Article 46.05 applies (motion filed 2012); appeal permitted and medication order is intertwined with competency finding | Former statute governs earlier proceedings; medication order separate and non-appealable interlocutory order | CCA has jurisdiction: 2007 statute applies to 2012 motion and medication order is reviewable as intertwined with competency finding |
| Whether the trial court had authority under Article 46.05 to order involuntary medication to render Staley competent | Article 46.05 does not authorize involuntary medication; competence achieved by forcible medication is invalid if the order lacked authorization | Trial court has inherent/judicial power to effectuate sentence and enforce judgment, including actions necessary to carry out execution | Trial court exceeded authority: Article 46.05 only authorizes periodic reexamination; no implicit power to order forcible medication under that statute |
| Whether any other statute or procedure authorized post-conviction involuntary medication here | No alternative statutory procedure was invoked (competency-to-stand-trial provisions or prison administrative process not used) | State contends enforcement of judgment and public interest support medication order | No other applicable statutory mechanism was invoked or demonstrated; administrative or inpatient-commitment procedures (where applicable) were not followed |
| Whether, absent the involuntary-medication order, evidence supports a finding of competency | Competency was produced solely by forced medication; without the order evidence shows incompetence | State urged that cause of competency (medically aided or not) is immaterial if defendant currently meets statutory competency criteria | Evidence conclusively shows Staley would be incompetent but for the unauthorized medication; competency finding and medication order vacated |
Key Cases Cited
- Ford v. Wainwright, 477 U.S. 399 (U.S. 1986) (constitutional prohibition on executing the insane; competency-to-be-executed standards)
- Panetti v. Quarterman, 551 U.S. 930 (U.S. 2007) (elaboration of substantive standard for execution competency)
- Sell v. United States, 539 U.S. 166 (U.S. 2003) (permitting involuntary medication for trial competency under narrow conditions)
- Washington v. Harper, 494 U.S. 210 (U.S. 1990) (due process framework for involuntary medication of inmates)
- Ex parte Caldwell, 58 S.W.3d 127 (Tex. Crim. App. 2001) (prior Article 46.05 interpretation limiting appeals of competency findings)
- Green v. State, 374 S.W.3d 434 (Tex. Crim. App. 2012) (Article 46.05 codifies Ford/Panetti constitutional standards)
- State v. Holloway, 360 S.W.3d 480 (Tex. Crim. App. 2012) (limits on post-conviction trial-court authority tied to statutory scope)
- Kelley v. State, 676 S.W.2d 104 (Tex. Crim. App. 1984) (discussion of judicial power to execute judgments)
- Boykin v. State, 818 S.W.2d 782 (Tex. Crim. App. 1991) (plain-text statutory interpretation approach)
- Dansby v. State, 398 S.W.3d 233 (Tex. Crim. App. 2013) (invalid judicial act cannot be the basis for downstream enforcement)