Wood v. Zahradnick

475 F. Supp. 556
CourtDistrict Court, E.D. Virginia
DecidedAugust 17, 1979
DocketCiv. A. No. CA75-0444-R
StatusPublished
Cited by1 cases

This text of 475 F. Supp. 556 (Wood v. Zahradnick) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wood v. Zahradnick, 475 F. Supp. 556 (E.D. Va. 1979).

Opinion

MEMORANDUM

MERHIGE, District Judge.

Respondent, Superintendent of the Virginia State Penitentiary, has filed a Rule 59(e), F.R.Civ.P. motion to alter or amend this Court’s July 9,1979 judgment granting petitioner Cecil Wood, Jr.’s petition for writ of habeas corpus. Petitioner has responded to respondent’s motion, and the matter is ripe for disposition.

In a previous opinion, filed March 29, 1977, this Court had held that, at and prior to his criminal trial in the Circuit Court of Nansemond County, Virginia, petitioner [557]*557had been denied his constitutional right to effective assistance of counsel. See, Wood v. Zahradnick, 430 F.Supp. 107 (E.D.Va. 1977). Despite the extremely unusual circumstances of the crimes of which petitioner had been charged and the bizarre actions of petitioner, petitioner’s trial attorney failed to investigate possible defenses relating to petitioner’s competency to stand trial or mental capacity at the time of the commission of the offense. The state convictions stemmed from petitioner’s rape and brutal beating of a 67 year old woman with whom he long and fondly had been acquainted.

Petitioner had consistently asserted throughout the criminal proceedings that, shortly before the crimes, he had taken several bags of heroin, had drunk bootleg whiskey, and that he did not remember committing any of the offenses. Without passing either upon the credibility of petitioner’s assertions or petitioner’s criminal responsibility for his actions, this Court specifically noted that “Dr. Davies, a psychiatrist, was of the opinion that the facts surrounding the crime are consistent with the medical condition termed alcoholic pathological intoxication.” Wood, supra, 430 F.Supp. at 112.

The Fourth Circuit Court of Appeals, while affirming this Court’s holding that petitioner had been denied the effective assistance of trial counsel, nonetheless remanded the case to give the state the opportunity to prove beyond a reasonable doubt that the trial lawyer’s failure to seek psychiatric examination of petitioner was harmless. “That would be established if psychiatric examination now may result in a competent determination that Wood is not now and was not then Subject to a psychotic reaction to alcohol.” Wood v. Zahradnick, 578 F.2d 980, 982 (4th Cir. 1978).

After hearing testimony from one psychiatrist, who had examined petitioner for possible alcoholic pathological intoxication, and from another psychiatrist, who had reviewed the facts of the case, as well as the tests and results, this Court concluded that the psychiatric examination did not lead to a competent determination that petitioner was not subject to psychotic reaction to alcohol at the time of the commission of the offenses. This Court, therefore, in its July 9, 1979 memorandum and order, issued a writ of habeas corpus, declaring petitioner’s February 14, 1972 state court convictions and sentences to be null and void and ordering respondent to release petitioner from further custody arising from those convictions.

Respondent does not ask this court to alter or amend that portion of the judgment ordering issuance of the writ. Respondent notes, however, that this court ordered respondent to release petitioner from further state custody arising from the February 14, 1972 convictions, without giving the state the opportunity to retry petitioner. Respondent has moved the court to amend or alter its judgment so as to declare that the state may retry petitioner within a reasonable time.

In support of his motion to alter or amend judgment, respondent contends that there is abundant case law which stands for the proposition that the state should be given an opportunity to retry the petitioner despite this court’s holding that the seven year delay between the commission of the offenses and the psychological testing of petitioner deprived petitioner of his “right to assert a defense of having suffered a psychosis at the precise time of the offenses.” Mem. op. at 6.

Respondent cites the following cases as support for his assertion that retrial and redetermination of mental competency is permissible even if, as in this case, several years have elapsed between the original trial and the grant of habeas corpus relief: Drope v. Missouri, 420 U.S. 162, 95 S.Ct. 896, 43 L.Ed.2d 103 (1975); Pate v. Robinson, 383 U.S. 375, 86 S.Ct. 836, 15 L.Ed.2d 815 (1966); United States v. Ives, 574 F.2d 1002 (9th Cir. 1978); Bruce v. Estelle, 536 F.2d 1051 (5th Cir. 1976), cert denied, 429 U.S. 1053, 97 S.Ct. 767, 50 L.Ed.2d 770 (1977); Tillery v. Eyman, 492 F.2d 1056 (9th Cir. 1974; Clark v. Beto, 415 F.2d 71 (5th [558]*558Cir. 1969); Roach v. Bennett, 319 F.Supp. 79 (S.D.Iowa, 1970); White v. Rhay, 266 F.Supp. 270 (E.D.Wash.1966), aff’d. 385 F.2d 883 (9th Cir. 1967).

The courts in each of the cited cases dealt with an alleged inadequate determination of a criminal defendant’s mental competency either to stand trial or to enter a guilty plea. These cases are inapposite to the issue in this case. The question here, after remand from the Court of Appeals, is not whether petitioner was competent to stand trial, but whether petitioner was suffering from alcoholic pathological intoxication when he committed the October 31, 1971 offenses, and was thus not criminally responsible under Virginia law for his actions. A person’s mental competency to stand trial and his mental condition at the time the offenses were committed are two fundamentally different issues.

Because a person’s mental condition may either improve or deteriorate over time, one who was not mentally competent to stand trial when originally tried may nonetheless be mentally competent to stand trial at a point in time several years thereafter. In recognition of this fact, the courts in the cases cited by respondent have, several years after the defendants’ trials, allowed states to retry criminal defendants upon determinations that the defendants, at the time of the new trials, were mentally competent to stand trial.

In contrast, a defendant’s criminal responsibility for his actions, unlike his mental competency to stand trial, relates solely to his mental condition at the time he committed the offenses.

The Fourth Circuit Court of Appeals has clearly articulated this basic distinction.

Whether a person charged with crime is mentally competent to stand trial is a discrete question, governed by different medical and legal standards from the question of mental responsibility.

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475 F. Supp. 556, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wood-v-zahradnick-vaed-1979.