A superior court’s failure to initiate a mental competency proceeding leads the Supreme Court today to reverse the death sentence and the underlying murder conviction in People v. Wycoff. The proceeding was necessary even though the “defendant presented as a person who very much understood what was happening around him and who had a relatively sophisticated ability to navigate the criminal justice system.” The court also rules out “a retrospective competency trial.”
After representing himself at trial, the defendant was sentenced for killing his sister and brother-in-law in Contra Costa County in 2006. He admitted the murders to the police and separately to a newspaper reporter, saying that his brother-in-law was a “communist” and “way over to the left,” that he needed to eliminate “bad people” who were politically “liberal,” and that he used a knife and a wheelbarrow handle for the killings “because he did not want the murders to be ‘another statistic that liberals could use’ to argue in favor of gun control.”
During the trial’s penalty phase, the defendant claimed he was a “good person” because he didn’t also kill the victims’ children. One of those children spoke at his uncle’s sentencing hearing, saying the death penalty shouldn’t be imposed because it would be wrong “to kill a crazy person.”
The court’s unanimous opinion by Justice Martin Jenkins holds a competency proceeding was required because “the [superior] court was presented with substantial evidence of defendant’s mental incompetence — specifically, his inability, due to mental illness, to consult rationally with counsel.” The evidence included a psychologist’s detailed report that concluded the defendant was incompetent to stand trial. The court stated that the trial judge’s “own observations of the defendant’s competence cannot take the place of the formal competence inquiry.”
This is Justice Jenkins first death penalty opinion and his second opinion overall (see here).