Wood v. Thaler
2011 U.S. Dist. LEXIS 57369
| W.D. Tex. | 2011Background
- Wood, a Texas death row inmate, was convicted of capital murder related to a January 1996 armed robbery and the killing by an accomplice.
- He sought a Panetti/Ford-based claim arguing he is incompetent to be executed, prompting a stay and an evidentiary hearing in November 2010.
- The court found his claim of a current delusional belief system rendering him unable to understand the basis for his execution to be incredible.
- Petitioner’s competing expert reports (Roman) diagnosed a persecutory delusional disorder; respondent’s experts (Conroy, Bailey) rejected delusion and found rational understanding.
- The court ultimately denied habeas relief, vacated the prior stay, and declined to issue a certificate of appealability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Threshold showing of insanity required by Panetti | Wood asserts Panetti-vs-Quarterman applies and requires merits review. | State argues lack of credible delusion and no need for federal review beyond procedural defaults. | Wood entitled to meritorious review on the Panetti claim |
| Burden of proof for incompetence to be executed | Petitioner bears burden to prove incompetence by preponderance. | Texas law places the burden on Wood to prove incompetence by preponderance. | Petitioner bears the burden; evidence insufficient to render incompetent |
| Credibility of petitioner's delusional conspiracy theory | Roman opined a persecutory delusional disorder linking execution to conspiracy. | Conroy and Bailey found no delusion; conspiracy theory lacked specifics and culture-context failed DSM criteria. | Court rejected delusional-disorder diagnosis; theory viewed as rationalization |
| Rational understanding of crime and execution | Petitioner may not rationally link his crime to his execution due to delusions. | Experts found petitioner has accurate, rational understanding of the factual and legal bases for conviction and death sentence. | Court found petitioner has rational understanding; no incompetence |
| Certificate of Appealability | Petitioner should receive COA if reasonable jurists could debate the decision. | Court should deny COA given lack of debatable constitutional claims. | COA denied |
Key Cases Cited
- Panetti v. Quarterman, 551 U.S. 930 (U.S. 2007) (insanity standard and due-process requirements for execution)
- Ford v. Wainwright, 477 U.S. 399 (U.S. 1986) (execution of the insane is unconstitutional; due process considerations)
- Cooper v. Oklahoma, 517 U.S. 348 (U.S. 1996) (burden of proof for insanity to stand trial or be executed)
- Medina v. California, 505 U.S. 437 (U.S. 1992) (competence standards and due process for execution)
- Ruiz v. Quarterman, 504 F.3d 523 (5th Cir. 2007) (procedural default and due process in Panetti-style claims)