In State v. Wadsworth, No. 16-1775 (Iowa Ct. App. May 16, 2018), the defendant, Norman Wadsworth, appealed his second degree murder conviction, arguing that the evidence at trial was insufficient to support the jury verdict and that he was not competent to stand trial.
Wadsworth could not get along with the manager at his apartment complex, Darlene Crook. He believed Crook was involved in a government conspiracy to kill him. Eventually, Wadsworth was evicted from his apartment and became homeless following his eviction. After several months of homelessness, he went back to the apartment, found Crook in her office and attacked her with a knife. Crook suffered several stab wounds and died from blood loss. On appeal, Wadsworth did not dispute killing Crook.
Wadsworth had schizophrenia for several years and received no treatment for his condition. After attacking Crook, he told police officers he contemplated killing Crook for some time. Wadsworth informed the officers that he heard voices in his head telling him to stab Crook. He admitted hearing voices in his head for thirty years but denied symptoms of mental illness. When his defense attorneys tried to talk to him regarding the details of the crime to formulate his defense, Wadsworth shut down the conversations.
Before trial, Wadsworth’s attorneys moved for a hearing to determine his competency because of the difficulties they had communicating with him. They offered the testimony of psychologist Alan Goldstein, who examined Wadsworth for eight hours over two days. In conducting his evaluation of Wadsworth, Goldstein administered numerous psychological tests, reviewed multiple records, interviewed members of Wadsworth’s family, prepared a 12-page report, and testified that Wadsworth was delusional, in need of medication, and not competent to assist in his defense. The State offered the testimony of their own medical expert, psychiatrist Michael Taylor, who examined Wadsworth for 90 minutes. In conducting his evaluation of Wadsworth, Taylor prepared a two-page report, and testified at the competency hearing that Wadsworth was capable of aiding his attorneys in a rational and meaningful manner. Further, Taylor concluded that Wadsworth was competent to stand trial. Dr. Taylor’s report also included comments that the court of appeals deemed “less than professional” and he lost his professional license to practice medicine before the trial.
At the competency hearing, the district court found Wadsworth competent to stand trial. The case proceeded to a jury trial, where Wadsworth was found guilty of murder in the second degree. Wadsworth appealed his conviction, contending there was insufficient evidence and that he was not competent to stand trial. The Iowa Court of Appeals reversed the conviction, holding that Wadsworth was not competent to stand trial.
The court of appeals noted the district court emphasized Wadsworth’s ability to sit quietly through the competency hearing. The appellate court signaled that the principal concerns in making a competency determination should be Wadsworth’s understanding of the proceedings against him, his ability to assess his options, confer with his attorneys, and to inform defense strategies.
The court of appeals concluded that although the evidence presented at the trial was sufficient to support Wadsworth’s second degree murder conviction, the issue of Wadsworth’s competency implicated his constitutional rights and superseded the sufficiency question. The Court discussed Dr. Goldstein’s opinions favorably and contrasted them with the “hands-off approach” of the State’s medical expert witness (Taylor), who examined Wadsworth for far less time. The Court also noted that Taylor made inappropriate comments in his report, and eventually lost his professional license, in finding a lack of support for a conclusion that Wadsworth was capable of effectively assisting in his own defense. The Court agreed “with Dr. Goldstein that Wadsworth’s lack of insight into his mental illness would interfere with his ability to assist in his defense.” It found Dr. Goldstein’s opinions credible and concluded Wadsworth’s untreated schizophrenia hindered his ability to meaningfully assist in his defense, rendering him incompetent to stand trial.