State Of Washington, V. Josiah Paul Sweeney

CourtCourt of Appeals of Washington
DecidedMarch 4, 2025
Docket57944-8
StatusUnpublished

This text of State Of Washington, V. Josiah Paul Sweeney (State Of Washington, V. Josiah Paul Sweeney) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Of Washington, V. Josiah Paul Sweeney, (Wash. Ct. App. 2025).

Opinion

Filed Washington State Court of Appeals Division Two

March 4, 2025

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 57944-8-II

Respondent,

v. UNPUBLISHED OPINION

JOSIAH PAUL SWEENEY,

Appellant.

CHE, J. ⎯ Josiah Sweeney appeals his convictions for two counts of aggravated first

degree murder, first degree burglary, and felony violation of a protective order.

Before trial, Dr. Michelle Hart evaluated Sweeney for competency. Dr. Hart determined

that Sweeney was competent to stand trial and that he presented with no active symptoms of a

mental illness. Before sentencing, Dr. Alexander Patterson evaluated Sweeney multiple times.

After trial and for the purposes of sentencing, Dr. Patterson submitted a report and was “fairly

confident [] Sweeney meets criteria for schizophrenia.” Clerk’s Papers (CP) at 449 (emphasis

omitted).

On appeal, Sweeney argues that (1) sentencing defendants with severe, diagnosed but

untreated, mental illness to life in prison without the possibility of parole is cruel punishment

under the federal and state constitutions, (2) he was deprived of effective assistance of counsel

because his attorney failed to produce evidence that a mental illness prevented him from forming No. 57944-8-II

the requisite mental state to commit the charged crimes and also failed to propose a diminished

capacity instruction, and (3) we should strike the crime victim penalty assessment (VPA).

We affirm the convictions but remand for the trial court to strike the VPA.

FACTS

I. BACKGROUND

In October 2021, law enforcement officers conducted a welfare check at the home of

Michael and Patricia Sweeney.1 In the home, they found the bodies of Michael and Patricia

Sweeney, who had been stabbed to death. They also found Michael and Patricia Sweeney’s son,

Josiah Sweeney, asleep in another room. At the time, there was a no-contact order in effect,

prohibiting Sweeney from contacting Michael Sweeney or going to his father’s home.

Detectives Kyle Kempke and Howard Reynolds detained and interviewed Sweeney. In the

interview, Sweeney denied either stabbing or knowing what happened to his parents.

The State charged Sweeney with two counts of aggravated first degree murder, first

degree burglary, and felony violation of a protective order. All counts carried a deadly weapon

enhancement and a domestic violence allegation.

In January 2022, at the request of Sweeney’s counsel, the trial court ordered a

competency evaluation for Sweeney because “Sweeney has significant memory issues and

possibly processing issues that may interfere with his ability to assist in his defense. [] Sweeney

has demonstrated an inability to retain information communicated by [his attorney] as well as an

inability to recall past events.” CP at 41-42. The competency evaluation order provided that the

1 Because the last name is shared between Josiah Sweeney and his parents, we use “Sweeney” to refer to the appellant, Josiah Sweeney, while we refer to his parents by their first and last name.

2 No. 57944-8-II

evaluation shall include, among other things, “[a] diagnosis or description of the current mental

status of the defendant.” CP at 44.

In February 2022, Dr. Michelle Hart evaluated Sweeney and filed a competency report.

Her evaluation included, among other things, conducting an hour-long interview and mental state

examination of Sweeney and reviewing available records such as notes made by jail mental

health staff, from when Sweeney was previously incarcerated, which stated that Sweeney

“‘appears confused and unsure when answering . . . questions,’” and that he “‘may be

minimizing symptoms of [mental illness].’” CP at 55. Dr. Hart’s report provided that Sweeney

“demonstrated intact attention and concentration. His memory was intact for short-term, recent

and remote. His intellectual functioning likely fell no lower than the average range, based on his

vocabulary, abstract reasoning skills, and fund of information.” CP at 56. The report further

provided, “Sweeney presented in this evaluation with no active symptoms of mental illness.” CP

at 56. Dr. Hart concluded that Sweeney was competent to stand trial. Based on Dr. Hart’s

report, the trial court found Sweeney competent.

The matter proceeded to a jury trial and witnesses testified consistently with the facts

above. Additionally, Detective Kempke testified that Sweeney was “very calm and sort of

without emotion” during the beginning of the interview with Detectives Kempke and Hamilton.

3 Rep. of Proc. (RP) (Jan. 23, 2023) at 1332. However, Detective Kempke stated that Sweeney,

when presented thereafter with “difficult and uncomfortable questions” from the detectives,

“would hunch forward and had his hands—I guess it’s called steepled where he would have his

fingers together, and he would be shaking, and his legs were shaking so that his entire body was

3 No. 57944-8-II

trembling.” 3 RP (Jan. 23, 2023) at 1333.2 Kempke also described Sweeney as chewing on his

tongue during these moments. According to Kempke, Sweeney’s presentation was not

consistent:

So we could be in the middle of him shaking and trembling and there would be numerous occasions where he would -- you could see his entire body just stop. He would sit up, his whole demeanor would change, and he would start talking about going back to school or how he was gonna get to work or something completely not associated with the question that he’d just been asked.

3 RP (Jan. 23, 2023) at 1334.

In January 2023, jury trial commenced and the jury convicted Sweeney on all charges.

II. SENTENCING

In Sweeney’s sentencing brief, Sweeney argued that a sentence of life without the

possibility of parole would be categorically unconstitutional as to individuals suffering from

severe mental illnesses under the constitutional prohibition on cruel punishment, and Sweeney

argued that he was suffering from such an illness. Sweeney largely argued that persons suffering

under such mental illnesses are similar to children for sentencing purposes. Sweeney attached to

his sentencing brief a February 2023 report by Dr. Alexander Patterson.

Dr. Patterson generated the February 2023 report following Sweeney’s counsel’s request

to evaluate “apparent cognitive and/or psychiatric symptoms” Sweeney presented while detained

in jail and to do this evaluation for the purposes of sentencing mitigation. CP at 443. In

introducing his report, Dr. Patterson stated that Sweeney’s counsel “initially requested a

psychological evaluation to clarify the nature of these symptoms and to what degree they may

2 Detectives Kempke and Reynolds also assumed a hunched-over stance several times during their interrogation of Sweeney.

4 No. 57944-8-II

have contributed to [Sweeney’s] crimes.” CP at 443. Dr. Patterson explained that, in conducting

his evaluation, he had interviewed Sweeney three times between February 2022 and July 2022,

administered three different tests, reviewed Dr. Hart’s competency evaluation report which

discussed the jail mental health records, and also reviewed the case’s discovery materials. While

Dr. Patterson commented that “[d]iscovery information relevant to [] Sweeney’s mental health

was rather sparse,” he mentioned reviewing, among other things, comments made by Sweeney’s

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