Chenault v. Stynchcombe, No. 76-1214
| Court | United States Courts of Appeals. United States Court of Appeals (5th Circuit) |
| Writing for the Court | Before MORGAN and HILL, Circuit Judges, and NOEL; LEWIS R. MORGAN |
| Citation | 546 F.2d 1191 |
| Parties | Marcus Wayne CHENAULT, Petitioner-Appellant, v. Leroy N. STYNCHCOMBE, Sheriff of Fulton County, Respondent-Appellee. |
| Docket Number | No. 76-1214 |
| Decision Date | 10 February 1977 |
Page 1191
v.
Leroy N. STYNCHCOMBE, Sheriff of Fulton County, Respondent-Appellee.
Fifth Circuit.
Rehearing and Rehearing En Banc Denied March 10, 1977.
Randy Bacote, Atlanta, Ga., for petitioner-appellant.
Lewis R. Slaton, Dist. Atty., Carter Goode, Asst. Dist. Atty., Atlanta, Ga., for respondent-appellee.
Appeal from the United States District Court for the Northern District of Georgia.
Before MORGAN and HILL, Circuit Judges, and NOEL, District Judge. *
LEWIS R. MORGAN, Circuit Judge:
Petitioner Marcus Wayne Chenault appeals the denial of habeas corpus relief by the United States District Court for the Northern District of Georgia. On September 12, 1974, a state jury convicted petitioner
Page 1192
of the murder of Mrs. Martin Luther King, Sr. and Deacon Edward Boykin and of the assault of Mrs. Jimmie Mitchell. Having exhausted his state remedies, petitioner brought an action for habeas relief 1 in federal district court. The district court denied relief on fourteen allegations of error and stayed proceedings on error numbers fifteen and sixteen. 2Petitioner's primary contention of state error justifying federal relief focuses on the failure of the state trial court to empanel a special jury, pursuant to Ga.Code § 27-1502, to conduct a hearing on petitioner's competency to stand trial. Prior to indictment, petitioner's counsel moved that the court enjoin the grand jury from issuing a bill of indictment until the court conducted an inquiry into petitioner's competency to stand trial. Treating this motion to stay indictment as a special plea of insanity or of incompetency to stand trial, under Ga.Code § 27-1502, the trial court rejected it as premature. After the grand jury had issued an indictment, petitioner failed to enter a special plea of incompetency to stand trial, instead entering only a plea of not guilty by reason of insanity. The latter puts in issue one's sanity at the time of commission of the offense, not one's competency to stand trial. Orange v. State, 77 Ga.App. 36, 47 S.E.2d 756 (1948). Nevertheless, the trial court appointed two psychiatrists, one of whom was requested by petitioner, to conduct a mental examination. Upon examination of petitioner, 3 each psychiatrist found him competent to stand trial. The trial court, therefore, ordered no further examination or hearing on this issue.
Petitioner argues that the state trial court should have ordered a hearing pursuant to a statute that petitioner never even invoked at trial. Whether the state court violated a state law by not empaneling, sua sponte, a special jury, does not concern this panel. See Pennington v. Stynchcombe,428 F.2d 875 (5th Cir. 1970). Rather, we examine the trial court's failure to grant a hearing only to the extent that this failure violated federal constitution standards governing a determination of mental competency. The Supreme Court has recognized a defendant's constitutional right in an appropriate case to adequate procedures to determine his...
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People v. Gensler
...specific standard for the nature or quantum of evidence necessary to mandate a competency procedure (see, Chenault v. Stynchombe, 5 Cir., 546 F.2d 1191, 1192). The Federal Courts of Appeals, however, while employing somewhat varied terminology, have consistently required only that the infor......
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Dix v. Newsome, Civ. A. No. C80-826A.
...Drope v. Missouri, 420 U.S. 162, 180, 95 S.Ct. 896, 908, 43 L.Ed.2d 103 (1975); Lokos v. Capps, supra, at 1261; Chenault v. Stynchcombe, 546 F.2d 1191, 1192-3 (5th The first important factor the court will address is the existence of a history of irrational behavior on the part of the petit......
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Saldaño v. Director, CIVIL ACTION NO. 4:08-cv-193
...petitioner fails to raise a bona fide doubt as to his competency and, thus, does not hold a competency hearing. Chenault v. Stynchcombe, 546 F.2d 1191, 1193 (5th Cir.), cert. denied, 434 U.S. 878 (1977). In the present case, trial counsel raised the issue of Saldaño's competence out of an a......
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Lokos v. Capps, No. 79-2771
...the existence of a history of irrational behavior, defendant's demeanor at trial, and a prior medical opinion." Chenault v. Stynchombe, 546 F.2d 1191, 1192-93 (5th Cir. 1977), citing Drope, Page 1262 420 U.S. at 180, 95 S.Ct. at 908. Even one of these factors, standing alone, may, in approp......
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People v. Gensler
...specific standard for the nature or quantum of evidence necessary to mandate a competency procedure (see, Chenault v. Stynchombe, 5 Cir., 546 F.2d 1191, 1192). The Federal Courts of Appeals, however, while employing somewhat varied terminology, have consistently required only that the infor......
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Saldaño v. Director, CIVIL ACTION NO. 4:08-cv-193
...petitioner fails to raise a bona fide doubt as to his competency and, thus, does not hold a competency hearing. Chenault v. Stynchcombe, 546 F.2d 1191, 1193 (5th Cir.), cert. denied, 434 U.S. 878 (1977). In the present case, trial counsel raised the issue of Saldaño's competence out of an a......
-
Dix v. Newsome, Civ. A. No. C80-826A.
...Drope v. Missouri, 420 U.S. 162, 180, 95 S.Ct. 896, 908, 43 L.Ed.2d 103 (1975); Lokos v. Capps, supra, at 1261; Chenault v. Stynchcombe, 546 F.2d 1191, 1192-3 (5th The first important factor the court will address is the existence of a history of irrational behavior on the part of the petit......
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Lokos v. Capps, No. 79-2771
...the existence of a history of irrational behavior, defendant's demeanor at trial, and a prior medical opinion." Chenault v. Stynchombe, 546 F.2d 1191, 1192-93 (5th Cir. 1977), citing Drope, Page 1262 420 U.S. at 180, 95 S.Ct. at 908. Even one of these factors, standing alone, may, in approp......