Compton v. State
2005 Mo. App. LEXIS 1453, 172 S.W.3d 927, 2005 WL 2447168 (2005)
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Rule of Law:
Counsel is not ineffective for failing to investigate a defense of mental disease or defect if the defendant was voluntarily intoxicated at the time of the offense and demonstrated an understanding of the wrongfulness of their actions, as voluntary intoxication generally precludes such a defense under Missouri law.
Facts:
- On October 28, 2002, Mark Compton stole a vehicle belonging to a correctional officer, which was parked in front of the Taney County Sheriff's Department.
- When pursued by officers, Compton sped away, forced other vehicles into the shoulder to avoid head-on collisions, crossed traffic in the wrong lane, failed to stop for a red light, and skidded into a ditch.
- Compton did not voluntarily exit the vehicle and was observed by officers to have watery, bloodshot, and glassy eyes, smell of alcohol, and have poor balance; a subsequent blood alcohol test showed his BAC was .163%.
- Upon arrest, Compton stated to officers, "I'm really sorry. I'm stupid, I shouldn't have done it. If you f— would have given me a ride home I wouldn't have taken the car. I'm really sorry, I shouldn't have done it. I drank too much, I drank a quart of Vodka!"
- Compton later claimed that he suffered from bipolar disorder which was triggered by harassment from correctional officers immediately prior to taking the van, causing him to decide to tear up the van in anger.
Procedural Posture:
- Mark Compton was charged by information with tampering in the first degree and resisting arrest in a trial court.
- Mark Compton pled guilty to both charges.
- Mark Compton filed a Rule 24.035 motion (post-conviction relief motion) in the trial court, claiming his guilty pleas were not knowingly, intelligently, and voluntarily made due to ineffective assistance of counsel for failing to investigate his mental illness.
- The trial court (motion court) held an evidentiary hearing on Mark Compton's Rule 24.035 motion.
- The trial court (motion court) denied Mark Compton's motion.
- Mark Compton appealed the denial of his Rule 24.035 motion to the Missouri Court of Appeals, Southern District, as the appellant.
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Issue:
Does counsel render ineffective assistance by failing to investigate a defense of mental disease or defect when the defendant was voluntarily intoxicated and demonstrated an understanding of the wrongfulness of their actions at the time of the offense?
Opinions:
Majority - Nancy Steffen Rahmeyer
No, counsel does not render ineffective assistance by failing to investigate a defense of mental disease or defect under these circumstances. The court reasoned that Mark Compton's statements to the police officers clearly indicated he knew taking the patrol car was wrong, thereby failing to meet the standard of Missouri Revised Statute § 552.030.1, which requires a person to be incapable of knowing and appreciating the nature, quality, or wrongfulness of their conduct. Even assuming Compton’s claim of bipolar disorder was true, he failed to provide evidence that the disorder caused him to be incapable of understanding the wrongfulness of his actions. Furthermore, Compton admitted he was voluntarily intoxicated, and Missouri Revised Statute § 562.076.3 explicitly states that evidence of voluntary intoxication is not admissible to negate the mental state of an offense. Citing State v. Rhodes, the court affirmed that voluntary intoxication cannot provide an insanity defense unless a separate mental disease results in diminished capacity without the voluntarily ingested drugs. Since the proposed mental disease or defect defense had no merit, trial counsel was not ineffective for failing to investigate it, consistent with State v. Twenter.
Concurring - Prewitt
Justice Prewitt concurred in the majority opinion.
Concurring - Parrish
Justice Parrish concurred in the majority opinion.
Analysis:
This case reinforces the stringent requirements for establishing a mental disease or defect defense in Missouri, particularly when voluntary intoxication is involved. It clarifies that a defendant's own statements acknowledging wrongfulness can undermine claims of incapacity, and that mental health conditions, even if present, must be shown to directly cause an inability to understand the nature or wrongfulness of conduct, independent of voluntary substance use. The ruling also reiterates that defense counsel is not obligated to pursue defenses that are legally meritless, thereby defining the scope of effective assistance of counsel in challenging circumstances.
