Aaron Hecker v. State of Missouri

CourtSupreme Court of Missouri
DecidedNovember 7, 2023
DocketSC100084
StatusPublished

This text of Aaron Hecker v. State of Missouri (Aaron Hecker v. State of Missouri) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aaron Hecker v. State of Missouri, (Mo. 2023).

Opinion

SUPREME COURT OF MISSOURI en banc

AARON HECKER, ) Opinion issued November 7, 2023 ) Appellant, ) ) v. ) No. SC100084 ) STATE OF MISSOURI ) ) Respondent. )

APPEAL FROM THE CIRCUIT COURT OF LIVINGSTON COUNTY The Honorable Daren L. Adkins, Judge

Aaron Hecker appeals the circuit court’s overruling of his Rule 24.035 motion for

postconviction relief. Hecker pleaded guilty to one count of second-degree assault of a

special victim and one count of resisting arrest. In his Rule 24.035 motion, he alleged his

attorney was ineffective at both his guilty plea and sentencing proceedings in failing to

adequately address his competency to proceed. The circuit court denied relief. Because

the circuit court did not clearly err in concluding counsel was not ineffective in failing to

investigate Hecker’s competency at his guilty plea and sentencing proceedings, the

judgment is affirmed. Background

The State charged Hecker with two counts of second-degree assault of a special

victim, one count of resisting arrest, one count of unlawful possession of a firearm, and

one count of armed criminal action. The charges arose from an August 2017 incident in

which Hecker shot at two police officers while they were attempting to arrest him.

In March 2019, counsel entered a limited entry of appearance on Hecker’s behalf

for the limited purpose of representing him in guilty plea and sentencing proceedings. 1

Pursuant to a plea agreement, Hecker pleaded guilty to a single charge of second-degree

assault of a special victim and resisting arrest, and the other charges were dismissed.

At the guilty plea hearing, the circuit court questioned Hecker with the standard

colloquy. During a portion of the questioning, he testified he had been taking Vistaril,

Haldol, and Cogentin for around two months. He had taken the prescribed amounts of

such medications within the last 48 hours. Hecker said he could not recall an instance in

which such medications caused him to exercise poor judgment. He testified nothing

about his physical or mental health made it difficult to understand or answer the court’s

questions. Hecker acknowledged he understood the rights he was giving up by entering a

guilty plea.

After questioning Hecker, counsel explained the original plea offer was given and

explained to Hecker more than three months prior. Counsel was then relieved of his

position as Hecker’s attorney. Subsequently, Hecker’s family contacted counsel to

1 Counsel previously entered his appearance for Hecker in January 2018 but withdrew in December 2018. 2 reinstitute plea negotiations. Counsel stated, “And he and I have met within the last three

weeks on a number of occasions to discuss getting the plea offer back on the table.”

Hecker and counsel “met multiple times” to discuss the plea proposal after it was offered.

The circuit court found Hecker’s guilty pleas were made freely, voluntarily, and

with knowledge of the rights he was waiving and found a factual basis for the pleas. 2

The court accepted the pleas and ordered a sentence assessment report (“SAR”). Counsel

subsequently filed a letter written to the Missouri Department of Probation and Parole

noting: “Because of Mr. Hecker’s diagnosis and mental health issues, I have instructed

Mr. Hecker to not participate in any Sentencing Assessment Report interview.” Hecker

did not participate in the SAR interview.

At Hecker’s sentencing hearing in July 2019, counsel argued Hecker had been

diagnosed with schizophrenia prior to August 2017 and medical records predating the

incident showed Hecker threatened to commit suicide on multiple occasions. Counsel

contended Hecker was attempting to commit suicide in his encounter with the police

officers. Counsel filed a sentencing memorandum contending the circuit court should

consider Hecker’s schizophrenia as mitigating evidence. 3

2 Hecker stated the factual basis for his plea to the court. He took a pistol away from the side of his head and shot it at two police officers. He knew the police officers were there to attempt to arrest him and threatened to shoot himself to prevent them from arresting him. He then fired in the direction of the police officers. 3 Included as an exhibit to the memorandum was a “Brief Assessment of Cognition” report prepared by a doctor at the Hedrick Medical Center following Hecker’s arrest. The report noted Hecker’s diagnosis of schizophrenia and his past mental health treatment. A supplement to the sentencing memorandum noted Hecker was transferred from Hedrick Medical Center to Mosaic Life Care Center for a possible 96-hour hold for mental health issues. The supplement also stated Hecker previously had been found 3 The circuit court asked Hecker if he would like to make a statement. Counsel

responded, “Mr. Hecker does not, Your Honor. Because of his mental health disease, on

my recommendation, Mr. Hecker will not make a statement.” Hecker stated, “I do have

something to say.” Counsel expounded:

I believe the Rules of Ethics provided that this decision as to whether Mr. Hecker makes a statement during sentencing rests with counsel and not with the Defendant. I accept full responsibility and it’s my decision, not Mr. Hecker’s. He suffers from schizophrenia and he will make outlandish statements if under stress.

The court observed that Hecker made statements during the plea hearing without trouble.

Counsel replied, “Is he competent? He’s competent. He’s competent. That’s not the

argument. I do not want the [c]ourt to take a negative or make a negative inference

against Mr. Hecker based on my advice to him and my recommendations to you. That is

all.” Hecker did not make a statement. The circuit court sentenced Hecker to 15 years on

the first count and four years on the second count with the sentences to run consecutively.

Hecker filed a pro se motion for postconviction relief under Rule 24.035. An

amended motion was timely filed, alleging Hecker received ineffective assistance of

counsel at sentencing and at his guilty plea because counsel failed to investigate his

mental health to determine if he was competent to proceed.

At the evidentiary hearing on the Rule 24.035 motion, counsel testified he never

asked the court to evaluate Hecker for his competence to proceed. Counsel was aware

incompetent to stand trial on charges in Kansas but was deemed competent in 2017 after being administered psychotropic medication.

4 Hecker was found incompetent in Kansas but had his competence restored. Counsel met

with Hecker on “multiple occasions.” He had conversations with Hecker about receiving

mental health treatment and whether Hecker was taking medications. Counsel testified:

Before I got very far into the file, one of the things I looked into was made sure I had in my file the Missouri statutes that dealt with the issue of mental competency as well as NGRI. And when I met with Mr. Hecker in the jail, I had that issue in my mind and always observed, assessed for whether or not it appeared to be Mr. Hecker understood the conversations that we were having, understood the charges that were pending against him and whether or not I believed he was capable of participating in his own defense.

Counsel believed Hecker understood the charges, the range of punishment, and the

elements of the crime. He went over template jury instructions with Hecker more than

once. Counsel spoke with Hecker twice in person about trying to regain the previously

withdrawn plea offer.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Clayton v. State
63 S.W.3d 201 (Supreme Court of Missouri, 2001)
Henderson v. State
977 S.W.2d 508 (Missouri Court of Appeals, 1998)
State v. Carter
955 S.W.2d 548 (Supreme Court of Missouri, 1997)
Woods v. State
994 S.W.2d 32 (Missouri Court of Appeals, 1999)
Straitway Transport, Inc. v. Mundorf
6 S.W.3d 734 (Court of Appeals of Texas, 1999)
Booker v. State
552 S.W.3d 522 (Supreme Court of Missouri, 2018)
Anderson v. State
564 S.W.3d 592 (Supreme Court of Missouri, 2018)

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