Commonwealth v. Graves

88 Va. Cir. 32, 2013 Va. Cir. LEXIS 150
CourtPrince William County Circuit Court
DecidedNovember 7, 2013
DocketCase Nos. CR. 10-3217-00, CR. 10-3217-02, CR. 10-3217-03, CR. 12-4235-00, CR. 12-4235-02, CR. 12-4235-03, CR. 12-4235-04
StatusPublished

This text of 88 Va. Cir. 32 (Commonwealth v. Graves) is published on Counsel Stack Legal Research, covering Prince William County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Graves, 88 Va. Cir. 32, 2013 Va. Cir. LEXIS 150 (Va. Super. Ct. 2013).

Opinion

By Judge Craig D. Johnston

I write to announce my decision following the hearing on October 21, 2013.

Summary

Having considered the evidence and argument, I find that Mr. Graves, the party alleging incapacity, has not met his burden of proving by the preponderance of the evidence that he is not competent to stand trial as to the captioned charges. He has not demonstrated under the statutory requirements as discussed in Orndorff v. Commonwealth, 271 Va. 486, 628 S.E.2d 344 (2006), that he lacks substantial capacity to understand the criminal proceedings against him or that he is incapable of assisting counsel in his defense.

Summary of Bases for Decision

The first and principal basis for my decision is that I find the testimony and the opinions of Dr. Hoffman, who opined that Mr. Graves is not incompetent, to be more credible and more persuasive than that of Dr. Peterson, who opined that he is not competent. This basis is independent of [33]*33the other two and sufficient to find that Mr. Graves has not met his burden of proof that he is unable to assist counsel in his defense.

A second, independent basis is my conclusion that, whatever issues Mr. Graves may have with his counsel and whatever their cause, he has the capacity to represent himself and both the desire and a constitutional right to do so.

A third, independent basis results from my conclusion that any undertaking to make a determination that Mr. Graves is “incapable of assisting counsel in his defense,” based upon behavior arising from sincerely held religious beliefs, must be carefully scrutinized, and is inappropriate in this case.

Procedural Background

In Case No. CR 10-3217, Mr. Graves has in the past represented himself, but consented to the appointment of counsel, who filed the original competency motion. Following this original request and following an evaluation by Dr. Peterson and a hearing, I found that Mr. Graves had not met his burden of proof that he was not competent to stand trial. Part of the basis for my so finding was that, while Dr. Peterson opined that he was unable to assist counsel, she could point to no particular mental health condition which rendered him incompetent, but rather based her decision upon his religious beliefs and his distrust of the system and those in it.

Mr. Graves’ counsel in Case No. CR 10-3217 filed motions to reconsider this ruling, citing the after-discovered report of Dr. King which, while it did not address or opine as to competency, contained opinions which might have been relevant to a competency determination. Mr. Graves’ counsel in Case No. CR 12-4235 joined in this request and filed a separate Motion for Competency Evaluation and Hearing. As a result, I reopened the competency proceedings in Case No. CR 10-3217 and granted the request for a new evaluation. A new evaluation was performed by Dr. Hoffman, who filed a report. A hearing was held, which was in part a continuation of the prior proceedings, now reopened, and in part new proceedings. It was agreed that evidence received in the prior hearing would be in evidence in the new proceedings, including both testimony and exhibits. All three doctors testified at the second hearing. Following the hearing, I took the matter under advisement and report my decision herein.

The various “02, 03” etc. charges are failure to appear charges which appear to remain pending.

[34]*34 Discussion

I. Dr. Hoffman’s Testimony and Conclusions

Without detailing all of the reasons that I find Dr. Hoffman’s testimony and opinions more persuasive, I will note some of them.

Dr. Hoffman performed the most recent evaluation.

All three doctors heard the testimony of the others. Dr. Hoffman testified last and was not persuaded by the opinion of Dr. Peterson that Mr. Graves lacked the ability to assist counsel.

Dr. King did not perform a competency evaluation, nor did he express an opinion as to competency. He did do testing, from which he concluded that Mr. Graves suffered from a disorder. Dr. Hoffman heard Dr. King’s testimony and his opinion, and, while he did not disagree with Dr. King’s opinion that Mr. Graves has this disorder, this did not change his opinion, nor persuade him that this disorder renders Mr. Graves unable to assist his counsel or otherwise incompetent.

Competency proceedings have as their central purpose and function to ensure that the constitutional and statutory rights of a defendant are met. The statutory right, which attempts to track the constitutional right, is that “No person shall, while he is insane or feebleminded, be tried for a criminal offense.” Virginia Code § 19.2-167.

The words of the statute are somewhat old-fashioned, and the psychological parlance has changed, but the essence has not — persons can be too deficient in intellectual capacity or too psychotic or otherwise psychologically disturbed, to be able to defend themselves or to assist their counsel, and, in such cases, it is not fair to require them to go to trial in that condition.

No expert opined that Mr. Graves is “feebleminded,” that is, that he is deficient in intellectual capacity, or that he lacked substantial capacity to understand the criminal proceedings against him. On the contrary, all opined that he is of average, and nearly above-average, intelligence and understood well the criminal proceedings against him.

No expert opined that Mr. Graves is “insane.” In more modern parlance, no expert opined that he suffered from any psychosis such as paranoid schizophrenia. He has never been hospitalized for any mental or emotional condition nor diagnosed with any mental or emotional condition which would usually require hospitalization. In his many appearances before me, he has never said or done anything which would cause me to question his sanity. The many motions he has filed and the many he has argued before me support the conclusion that he is not insane, nor feebleminded, and fully understands the proceedings against him and the legal process.

That leaves the last question, which is the principal issue in this case, which is whether Mr. Graves is “unable” to assist his counsel. Ordinarily, [35]*35persons evaluated for competency and found unfit to stand trial are found unfit because they meet the “insane” test, and they are further “unable to assist counsel” because they are insane. Where not insane, they must establish that they are nonetheless “unable” to assist counsel. To be “unable” to do something is different from “to have difficulty” in doing something. While Mr. Graves may have some mental health difficulties, this is not unusual for criminal defendants, and, while these difficulties, together with his religious beliefs, discussed below, may render it difficult for him to deal with counsel, I conclude based upon Dr. Hoffman’s opinion and the other evidence in the case that he has not met his burden of establishing that he is “unable” to assist counsel.

II. Right to Self-Representation

A further, independent, consideration is the question of Mr. Graves’ ability to represent himself. Dr. Hoffman is of the opinion that Mr. Graves has the capacity to represent himself. Exhibits 2 and 3, second to last paragraph.

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Related

Orndorff v. Com.
628 S.E.2d 344 (Supreme Court of Virginia, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
88 Va. Cir. 32, 2013 Va. Cir. LEXIS 150, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-graves-vaccprincewill-2013.