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Jonathan Huey Lawrencev.Secretary Florida Department Of Corrections, Et Al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.10-13862
DecidedOctober 30, 2012
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CriminalCriminal ProcedurePost-Conviction ReliefHabeas CorpusDeath PenaltySixth AmendmentDue ProcessIneffective Assistance of CounselExpert TestimonyStandard of ReviewDirect Appeal
Case Summary

Jonathan Huey Lawrence pleaded guilty in Florida to participating in the brutal murder of eighteen-year-old Jennifer Robinson and was sentenced to death after a penalty-phase jury recommendation. During the penalty phase, Lawrence reported flashbacks or hallucination-like experiences, but counsel and the trial judge concluded that he was distressed by the evidence rather than unable to understand the proceedings. In state postconviction proceedings, experts offered conflicting opinions about his competency, and the state courts denied relief. The Eleventh Circuit held that counsel’s decision not to request a competency hearing reflected reasoned professional judgment and that Lawrence could not show a reasonable probability of a different result under Strickland’s doubly deferential AEDPA standard. The Court separately reached the merits of Lawrence’s substantive competency claim because circuit precedent generally precluded procedural default of such claims. Applying Dusky and clear-error review, it held that schizophrenia, low intelligence, or disturbing behavior did not establish a present inability to understand the proceedings or assist counsel. The Court affirmed the district court’s denial of habeas relief.

Opinion

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