State v. Huckaby

495 So. 2d 404, 1986 La. App. LEXIS 7757
CourtLouisiana Court of Appeal
DecidedOctober 8, 1986
DocketNo. CR 86-241
StatusPublished

This text of 495 So. 2d 404 (State v. Huckaby) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Huckaby, 495 So. 2d 404, 1986 La. App. LEXIS 7757 (La. Ct. App. 1986).

Opinion

KING, Judge.

This appeal presents the issues of whether the defendant had the mental capacity to be tried and whether the evidence was sufficient to sustain a guilty verdict when the defendant claimed he was insane at the time of the offense.

Milbert Mangrum Huckaby (hereinafter referred to as defendant) was charged by grand jury indictment with second degree [406]*406murder, a violation of R.S. 14:30.1. The defendant pled not guilty and not guilty by reason ⅝ of insanity. After a trial by jury, he was found guilty as charged. The trial court sentenced defendant to the mandatory sentence of life imprisonment without benefit of probation, parole, or suspension of sentence. Defendant timely appealed his conviction, designating the following assignments of error:

(1) The trial court erred by requiring the defendant to go to trial, when one of the doctors of the sanity commission recommended the defendant be evaluated further for his present mental condition prior to the proceedings; and
(2) The evidence was insufficient to sustain a conviction since the evidence showed that the defendant was insane at the time of the offense.

For the reasons hereinafter set forth, we affirm the defendant’s conviction.

FACTS

On the evening of Friday, September 13, 1985, Melba Simmons, who shared a house with Cornelius “Bob” Huckaby and his son, the defendant, went outside to use the outhouse. After a few minutes, the defendant got up, left the house and walked outside. Shortly thereafter, Mr. Huckaby, who had been watching television, heard Ms. Simmons shout, “Bob, help me.” As he ran around the house, he saw Ms. Simmons trying to come towards him with the defendant standing behind her. When he told the defendant to leave her alone, Ms. Simmons fell face down. As Mr. Huckaby bent down to assist her, he noticed she was covered with blood. He looked back at the defendant, and saw that his son had a pocket knife in his hand. When Mr. Huc-kaby asked for defendant’s help in assisting Ms. Simmons, the defendant said, “Daddy, let her die.” As Mr. Huckaby persisted in his efforts to get the victim to a hospital, the defendant stepped towards him and “let out a crazy scream.” The defendant then ran away from the scene.

Sheriff's deputies later arrived and found the defendant inside the Huckaby residence sitting in a chair. The deputies noticed that the defendant’s clothes were stained with blood. After the defendant was twice read his rights, he led the deputies to the location where he stabbed Ms. Simmons. At that point, the deputies observed a large area of blood. The defendant was arrested and charged with the second degree murder of Melba Simmons, who died of multiple stab wounds.

ASSIGNMENT OF ERROR NUMBER 1

In this assignment of error, the defendant alleges that the trial court erred in requiring him to stand trial because one of the two members of the sanity commission recommended further evaluation of the defendant’s mental capacity.

A sanity commission, consisting of two physicians, was appointed to determine defendant’s mental capacity to stand trial. One of the physicians, Dr. Etienne Brown, found that the defendant was sane and was completely capable of assisting in his defense. Dr. Brown’s evaluation was based on a lengthy consultation with the defendant on November 19th, in which he determined that: “On this examination, the patient was ambulant, alert, and active. He was completely oriented as to the time and place and circumstances ... [T]he patient had shown no evidence of insanity and no evidence of mental incompetence at anytime.”

The defendant was evaluated by Dr. Gilíes Morin on November 7th. At this examination, the defendant was uncooperative and would not answer the doctor’s questions. Dr. Morin’s report stated that: “In my opinion, I felt that he did fulfill the Bennett criteria and did not answer or told me that he did not remember out of choice rather than out of some type of emotional problem. In all fairness, however, I feel that he should be in a maximum security hospital setting where he could be evaluated further with the use of psychological testing.”

On November 27th, a sanity hearing was held to determine defendant’s competency [407]*407to stand trial. Based on the reports of the sanity commission, the trial judge concluded that the defendant had the capacity to proceed to trial.

Defendant contends that when one of the doctors of a two-member sanity commission recommends that the defendant be further examined at a mental institution prior to requiring him to go to trial, the court should give the defendant the benefit of the doubt caused by the conflicting medical opinions.

Mental incapacity to proceed is defined in LSA-C.Cr.P. Art. 641 as follows:

“Mental incapacity to proceed exists when, as a result of mental disease or defect, a defendant presently lacks the capacity to understand the proceedings against him or to assist in his defense.”

The defendant carries the burden of showing that he is incompetent to stand trial by a clear preponderance of the evidence. State v. Machon, 410 So.2d 1065 (La.1982); State v. Weber, 364 So.2d 952 (La.1978); State v. Morris, 340 So.2d 195 (La.1976). The trial court’s determination as to the defendant’s capacity is entitled to great weight on appeal and will not be overturned absent an abuse of discretion. State v. Brogdon, 426 So.2d 158 (La.1983), aff’d 457 So.2d 616 (La.1984), cert. den., 471 U.S. 1111, 105 S.Ct. 2345, 85 L.Ed.2d 862, rehearing den., — U.S. -, 105 S.Ct. 3547, 87 L.Ed.2d 670 (1985); State v. Rochon, 393 So.2d 1224 (La.1981); State v. Sanders, 463 So.2d 1022 (La.App. 3rd Cir. 1985). Where there is conflicting medical testimony, the trial judge’s determination is entitled to especially great weight. State v. Williams, 381 So.2d 439 (La.1980); State v. Jones, 376 So.2d 125 (La.1979); State v. Morris, supra.

Defendant asserts that the court should have fully determined his mental capacity before proceeding with the trial since one of the doctor’s reports was inconclusive. It has been established that while a thorough mental examination is necessary, the final determination of a defendant’s competency to stand trial must rest in a judicial authority and is a legal issue rather than a medical issue. State v. Qualls, 377 So.2d 293 (La.1979). In making this determination, the judge should reach an independent evaluation of defendant’s capacity to participate in his defense, rather than depending on the conclusory reports of the sanity commission. State v. Jones, supra.

Since the final determination as to the defendant’s competency rests with the trial judge, the court’s decision cannot be overturned unless it is found to be clearly erroneous. The appropriate considerations that the trial judge should apply in determining the defendant’s capacity to proceed were outlined by the Louisiana Supreme Court in State v. Bennett, 345 So.2d 1129 (La.1977), where it stated:

“The decision as to a defendant’s competency to stand trial should not turn solely upon whether he suffers from a mental disease or defect, but must be made with specific reference to the nature of the charge, the complexity of the case and the gravity of the decisions with which he is faced.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Monk
454 So. 2d 421 (Louisiana Court of Appeal, 1984)
State v. Weber
364 So. 2d 952 (Supreme Court of Louisiana, 1978)
State v. MacHon
410 So. 2d 1065 (Supreme Court of Louisiana, 1982)
State v. Qualls
377 So. 2d 293 (Supreme Court of Louisiana, 1979)
State v. Brogdon
457 So. 2d 616 (Supreme Court of Louisiana, 1984)
State v. David
425 So. 2d 1241 (Supreme Court of Louisiana, 1983)
State v. Edwards
400 So. 2d 1370 (Supreme Court of Louisiana, 1981)
State v. Narcisse
426 So. 2d 118 (Supreme Court of Louisiana, 1983)
State v. Brogdon
426 So. 2d 158 (Supreme Court of Louisiana, 1983)
State v. Roy
395 So. 2d 664 (Supreme Court of Louisiana, 1981)
State Ex Rel. Graffagnino v. King
436 So. 2d 559 (Supreme Court of Louisiana, 1983)
State v. Morris
340 So. 2d 195 (Supreme Court of Louisiana, 1976)
State v. Rochon
393 So. 2d 1224 (Supreme Court of Louisiana, 1981)
State v. David
468 So. 2d 1126 (Supreme Court of Louisiana, 1984)
State v. David
468 So. 2d 1133 (Supreme Court of Louisiana, 1985)
State v. Guidry
450 So. 2d 50 (Louisiana Court of Appeal, 1984)
State v. Chapman
438 So. 2d 1319 (Louisiana Court of Appeal, 1983)
State v. Jones
376 So. 2d 125 (Supreme Court of Louisiana, 1979)
State v. Bennett
345 So. 2d 1129 (Supreme Court of Louisiana, 1977)

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Bluebook (online)
495 So. 2d 404, 1986 La. App. LEXIS 7757, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-huckaby-lactapp-1986.