State of Missouri v. Jesse Driskill
2015 Mo. LEXIS 26, 459 S.W.3d 412 (2015)
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Rule of Law:
A trial court has broad discretion in determining a defendant's competency to stand trial and is not required to order a new competency evaluation mid-trial due to a defendant's anxiety or panic attacks, provided the court makes sufficient inquiries and accommodations, and substantial evidence supports the finding that the defendant retains the capacity to understand the proceedings and assist counsel.
Facts:
- On July 25, 2010, Jesse Driskill was with Jessica Wallace by the Prosperine River when they were interrupted by a police officer, causing Driskill to flee into the woods with a gun.
- Contemporaneously, an elderly couple, J.W. (82) and C.W. (76), were at their country home approximately one and one-half miles away, celebrating their 59th wedding anniversary.
- The following day, July 26, concerned family members entered the couple's locked home and discovered their bodies under smoldering blankets.
- Police investigators found no signs of forced entry. C.W. had been sexually assaulted, shot, and her body was burned in the groin area. J.W. had a plastic bag over his head and had also been shot.
- The victims' vehicle was found burned in a nearby town, close to where Driskill had asked to be picked up.
- Driskill subsequently confessed to several acquaintances that he had committed a home invasion, robbed an elderly couple, murdered them both, and raped the woman.
- Driskill detailed his attempts to destroy evidence, including shaving and pouring bleach on C.W.'s body, setting fires inside the house, and later burning the victims' vehicle.
- DNA analysis of vaginal swabs from C.W.'s body revealed a mixture of DNA from C.W. and Driskill.
Procedural Posture:
- The State of Missouri charged Jesse Driskill in the trial court with two counts of first-degree murder and other related felonies.
- The state provided notice of its intent to seek the death penalty.
- Pre-trial, Driskill's counsel presented the court with two conflicting expert reports regarding Driskill's competency.
- During voir dire, defense counsel's motion for a competency evaluation following Driskill's panic attack was denied by the trial court.
- A jury found Driskill guilty on all counts.
- After the penalty phase, the jury recommended death sentences for both murders.
- The trial court imposed the two death sentences along with consecutive prison terms for the other counts.
- Driskill filed a direct appeal to the Supreme Court of Missouri, which has exclusive jurisdiction over death penalty cases.
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Issue:
Does a trial court violate a defendant's due process right to a fair trial by declining to order a mid-trial competency evaluation when the defendant, who suffers from anxiety and panic attacks, repeatedly requests to be absent from the courtroom but consistently demonstrates a rational understanding of the proceedings and an ability to consult with counsel?
Opinions:
Majority - George W. Draper III
No, a trial court does not violate a defendant's due process rights because a defendant is presumed competent, and the trial court's determination of competency will be upheld if supported by substantial evidence. Here, the trial court had two conflicting pre-trial expert reports and was within its discretion to credit the more recent report finding Driskill competent. The court also made extensive, independent inquiries throughout the trial, directly questioning Driskill, who consistently affirmed his ability to understand the proceedings and communicate with his attorneys. Furthermore, the court made significant accommodations for Driskill's anxiety, including granting recesses and allowing him to be absent from the courtroom when he requested. A defendant feeling 'uneasy' during a capital trial is not, in itself, sufficient evidence to rebut the presumption of competency.
Dissenting - Patricia Breckenridge
Yes, the trial court violated Driskill's rights because it failed to order a required competency examination when it had reasonable cause to doubt his fitness to proceed. The majority misframes the issue; the question is not whether Driskill was ultimately competent, but whether the evidence before the judge—including Driskill's documented mental health history, a panic attack during voir dire, and his expert's revised opinion expressing concern about his ability to assist counsel during such attacks—was enough to trigger the statutory duty to order an examination. The court's accommodations became insufficient during the penalty phase, where Driskill was absent for critical portions of the trial. The judge's personal observations and questioning cannot substitute for a formal, mandated competency evaluation when such significant doubts are raised.
Analysis:
This decision reinforces the high degree of discretion afforded to trial judges in determining a defendant's competency to stand trial. It establishes that a defendant's mental health issues, such as anxiety and panic disorders that manifest during trial, do not automatically necessitate a new formal competency evaluation if the court makes adequate inquiries and accommodations. The ruling distinguishes between a defendant's fundamental inability to understand proceedings versus a situational difficulty in participating, suggesting the latter can be managed without halting the trial. The dissent, however, highlights the critical legal threshold for when a judge's doubt should compel a formal evaluation, arguing that a defendant's repeated inability to physically remain in the courtroom crosses that line, especially in a capital case.
