Morrow v. State

928 So. 2d 315, 2004 WL 1909275
CourtCourt of Criminal Appeals of Alabama
DecidedAugust 27, 2004
DocketCR-01-1619
StatusPublished
Cited by52 cases

This text of 928 So. 2d 315 (Morrow v. State) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morrow v. State, 928 So. 2d 315, 2004 WL 1909275 (Ala. Ct. App. 2004).

Opinion

The appellant, John E. Morrow, was convicted of three counts of capital murder in connection with the death of Thomas Philyaw.1 The murder was made capital (1) because it was committed during the course of a kidnapping in the first degree, see § 13A-5-40(a)(1), Ala. Code 1975; (2) because it was committed during the course of a robbery in the first degree, see §13A-5-40(a)(2), Ala. Code 1975; and (3) because Philyaw was in a vehicle at the time of his death, see § 13A-5-40(a)(17), Ala. Code 1975. By a vote of 8-4, the jury recommended that Morrow be sentenced to life imprisonment without the possibility of parole. The trial court overrode the jury's recommendation and sentenced Morrow to death.

Morrow raises five issues on appeal; however, because of our disposition of this case, we address only two of those issues at this time.

I.
Citing Atkins v. Virginia, 536 U.S. 304, 122 S.Ct. 2242,153 L.Ed.2d 335 (2002), Morrow argues that his death sentence constitutes cruel and unusual punishment under theEighth Amendment to the United States Constitution because, he says, he is mentally retarded. (Issue II in Morrow's brief.) Although Morrow's sentencing occurred before the Supreme Court released its decision in Atkins, Morrow nevertheless argued at the sentencing hearing before the trial court that the execution of mentally retarded persons constitutes cruel and unusual punishment and that he could not be sentenced to death because he was, in fact, mentally retarded. Therefore, this issue was properly preserved for review.

In Atkins, the United States Supreme Court held: *Page 317

"We are not persuaded that the execution of mentally retarded criminals will measurably advance the deterrent or the retributive purpose of the death penalty. Construing and applying the Eighth Amendment in the light of our `evolving standards of decency,' we therefore conclude that such punishment is excessive and that the Constitution `places a substantive restriction on the State's power to take the life' of a mentally retarded offender. Ford [v. Wainwright], 477 U.S. [399,] 405 [(1986)]."
536 U.S. at 317, 122 S.Ct. 2242. The Alabama Legislature has not yet enacted legislation defining mental retardation for purposes of implementing Atkins. However, as this Court recognized inStallworth v. State, 868 So.2d 1128 (Ala.Crim.App. 2003), Alabama does have the "Retarded Defendant Act," § 15-24-1 et seq., Ala. Code 1975. Section 15-24-2(3), Ala. Code 1975, defines a mentally retarded person, for purposes of the Act, as "[a] person with significant subaverage general intellectual functioning resulting in or associated with concurrent impairments in adaptive behavior and manifested during the developmental period, as measured by appropriate standardized testing instruments."2 Moreover, in upholding the death sentence in Ex parte Perkins, 851 So.2d 453 (Ala. 2002) (opinion on remand from the United States Supreme Court), the Alabama Supreme Court applied the broadest definition of mental retardation recognized in those states that prohibit the execution of a mentally retarded defendant. The Court stated:

"Those states with statutes prohibiting the execution of a mentally retarded defendant require that a defendant, to be considered mentally retarded, must have significantly subaverage intellectual functioning (an IQ of 70 or below), and significant or substantial deficits in adaptive behavior. Additionally, these problems must have manifested themselves during the developmental period (i.e., before the defendant reached age 18)."

851 So.2d at 456. In Atkins, the Court noted that significant or substantial deficits in adaptive behavior are evidenced by "limitations in two or more of the following applicable adaptive skill areas: communication, self-care, home living, social skills, community use, self-direction, health and safety, functional academics, leisure, and work." Atkins,536 U.S. at 308 n. 3, 122 S.Ct. 2242.

At the penalty phase, Morrow presented evidence, through testimony and the introduction of some of his school records, indicating that he is mentally retarded. Specifically, the evidence presented indicates that Morrow repeated the first grade three times; that he had poor grades in school; that when he was 10 years old and in the second grade he was administered the Wechsler Intelligence Scale for Children and determined to be in the "educable mentally retarded range of intellectual functioning," with a verbal IQ of 65, a performance IQ of 68, and a full-scale IQ of 64; that when he was 13 years old, he *Page 318 was administered the Slosson Intelligence Test and determined to have an IQ of 67, although there were indications of arithmetic errors in the scoring of that test that suggested the score of 67 was "inflated"; that he suffered from "severe to moderate deficiencies" in "all areas and skills tested"; and that he was placed in special-education classes. The presentence report indicates that Morrow dropped out of school after the eighth grade.

Stanley Brodsky, a clinical and forensic psychologist, testified that he evaluated Morrow for trial, when Morrow was 32 years old, and administered the Kaufman Brief Intelligence Test ("the K-BIT"), as well as the Personality Assessment Inventory ("the PAI"). According to Dr. Brodsky, the K-BIT, although not a full-fledged IQ test, is a "screening" test designed to "estimate" a person's IQ. (R. 1065.) Dr. Brodsky testified that Morrow's score on the verbal portion of the K-BIT indicated a verbal IQ of between 53 and 65; that Morrow's score on the nonverbal portion of the K-BIT indicated a performance IQ of between 56 and 70; and that Morrow's overall score on the K-BIT indicated a full-scale IQ of between 51 and 63. Although numerically Morrow's scores fell within the moderate range of mental retardation, Dr. Brodsky said, when viewed in light of Morrow's IQ scores from the tests administered when he was child, he believed Morrow was not moderately retarded, but was "toward the bottom of the mildly mentally retarded range." (R. 1078.)

Dr. Brodsky testified that mentally retarded individuals often "learn ways of getting along with others, so the others don't know what's going on," such as pretending to understand things that are going on around them and being agreeable. (R. 1087.) During his evaluation, Dr. Brodsky said, Morrow exhibited signs indicating that he was pretending to understand things that were going on around him, when in fact he did not understand them. Dr. Brodsky also testified that people at Morrow's level of intellectual functioning have "a diminished intellectual appreciation of everything," including the wrongfulness and consequences of their actions. (R. 1094.) Dr. Brodsky also said that mildly mentally retarded individuals can have a wide range of abilities, depending on the individual person.

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Cite This Page — Counsel Stack

Bluebook (online)
928 So. 2d 315, 2004 WL 1909275, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morrow-v-state-alacrimapp-2004.