State v. M. Spell, 2017 MT 266

Background

In January 2012 Michael Spell and co-defendant Lester Waters traveled from Colorado toward North Dakota; Spell later confessed that Waters abducted and killed Sherry Arnold while she was jogging, and that Spell assisted in burying her body.
Spell was charged in Richland County with Aggravated Kidnapping, Deliberate Homicide, and Attempted Kidnapping; he pleaded not guilty and later pled guilty to Deliberate Homicide under a plea agreement.
Before trial, Spell moved to determine competency and whether a developmental disability rendered him unable to appreciate criminality or conform his conduct to the law; the District Court ordered a 60-day multidisciplinary evaluation at the Montana State Hospital.
State Hospital staff (Dr. Hill and a team) concluded Spell was competent to proceed; defense experts (Drs. Olley and Beaver) diagnosed intellectual disability (IQ ≈70) and opined impairment—Dr. Beaver also opined Spell could not conform conduct at the time of the offense.
The District Court held a competency hearing, found Spell competent to stand trial, accepted his guilty plea, and later sentenced him to 100 years in prison for Deliberate Homicide.
On appeal, Spell challenged (1) competency to stand trial, (2) whether his developmental disability prevented appreciation/conformity at the time of the offense (mandating commitment to DPHHS), and (3) whether a prison sentence violated Eighth Amendment / state dignity protections.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Spell)	Held
Competency to stand trial	Substantial evidence (multidisciplinary 60-day State Hospital evaluation and observations) shows Spell could consult with counsel and understood proceedings	Spell is intellectually disabled (IQ ~70; reading at 3rd-grade level) and experts testified he lacked capacity to assist/decide; prior Colorado finding of incompetence	Court: Competent — State Hospital observations and Dr. Hill’s findings provided substantial evidence that Spell had sufficient present ability to consult with counsel and rational/factual understanding of proceedings.
Mental disease/disability at time of offense (ability to appreciate wrongfulness / conform conduct)	Evidence shows Spell could appreciate wrongfulness and had ability to resist Waters; State Hospital clinicians found no defect so incapacitating as to prevent appreciation or alternatives	Spell’s intellectual disability, intoxication, and subservience to Waters rendered him unable to conform his conduct; Dr. Beaver recommended commitment to DPHHS	Court: No abuse of discretion — record supports finding Spell’s disability did not render him unable to appreciate or conform his conduct at the time of the offense.
Eighth Amendment / human dignity challenge to prison sentence	State: Sentencing to prison lawful; no controlling precedent requires commitment to treatment facility for intellectually disabled offenders	Spell: Sentencing to prison is cruel/unusual because prison cannot meet needs of intellectually disabled and he is susceptible to manipulation; analogies to cases addressing conditions of confinement	Court: Rejected — sentencing to prison did not violate cruel and unusual prohibition; Atkins bars death penalty only, and cited cases addressed conditions of confinement, not sentence legality.

Key Cases Cited

State v. McCarthy, 324 Mont. 1, 101 P.3d 288 (Mont. 2004) (competency standard—ability to consult with counsel and rational/factual understanding)
State v. Statczar, 228 Mont. 446, 743 P.2d 606 (Mont. 1987) (substantial-evidence review when evidence conflicts)
State v. Herman, 343 Mont. 494, 188 P.3d 978 (Mont. 2008) (review of criminal sentences imposing a year or more of incarceration)
State v. Gallmeier, 349 Mont. 424, 203 P.3d 852 (Mont. 2009) (burden on defendant to prove mental disease/disorder or developmental disability at time of offense)
State v. Burke, 329 Mont. 1, 122 P.3d 427 (Mont. 2005) (abuse-of-discretion standard for findings under § 46‑14‑311)
State v. Egdorf, 317 Mont. 436, 77 P.3d 517 (Mont. 2003) (plenary review of constitutional issues)
Wilson v. State, 358 Mont. 438, 249 P.3d 28 (Mont. 2010) (challenges to conditions of confinement by mentally ill inmates)
Walker v. State, 316 Mont. 103, 68 P.3d 872 (Mont. 2003) (conditions of confinement claims by mentally ill inmates)
Atkins v. United States, 536 U.S. 304 (U.S. 2002) (intellectually disabled defendants are categorically ineligible for the death penalty)