Andrew Lyons was sentenced to death by a Missouri state court after being convicted of two counts of first-degree murder and one count of involuntary manslaughter. The Missouri Supreme Court upheld both the convictions and the denial of Lyons's post-conviction relief motion. Subsequently, Lyons filed a habeas corpus application under 28 U.S.C. § 2254, which the district court denied, concluding that he was competent to stand trial, did not demonstrate ineffective assistance of counsel, and that any trial court error regarding the admission of his confession was harmless.
The case background reveals that in September 1992, Lyons lived with Bridgette Harris and her three children. His relationship with Harris deteriorated, leading to threats against her and her family, including comments about killing them. Following an argument with Harris, Lyons shot and killed Harris, her mother Evelyna Sparks, and their infant son Dontay. The police found the victims with gunshot wounds, confirming the lethal use of a shotgun identified as belonging to Lyons.
Lyons contacted his half-brother, Jerry DePree, for a ride after the shootings of Sparks, Harris, and Harris’s boyfriend, indicating he had killed them and accidentally killed another individual, Dontay. Upon arriving at the Carters’ house, Lyons disclosed the details of the shootings to Gail Carter and instructed DePree to keep the shotgun used in the killings, pick up his check, and avoid driving Lyons's vehicles due to police attention. DePree later surrendered the shotgun to the police, which was confirmed to be the murder weapon.
Lyons was arrested at Trail of Tears State Park later that afternoon. Upon law enforcement's arrival, he attempted to flee but stopped when threatened. He was read his Miranda rights, acknowledged understanding them, and claimed to have disposed of the gun in the river. After being placed in a patrol car, he inquired about obtaining a lawyer, prompting Deputy Vincent Diebold to affirm that he could do so. Lyons then expressed concern about whether anyone had died and later stated he "just snapped" during a conversation with Detective Judy Gentry, who provided him with a phone book to contact an attorney.
Initially, Lyons chose to call his sister, Lily Mae Foster, instead of an attorney. When Foster arrived, Lyons spoke about his history with Harris and their issues. Detective Gentry reminded Lyons that she had not yet questioned him about the incident. Eventually, either Lyons or Foster requested to speak to an attorney, leading Detective Gentry to offer a telephone book again. Lyons indicated he could not afford an attorney but was informed he could obtain a court-appointed one, deciding instead to wait until his court appearance.
Detective Gentry informed Lyons that she would not initiate further contact due to his request for an attorney, stating that any communication would need to come from him. Shortly after, Detective Gentry and others returned to escort Lyons to a holding cell, where Foster requested that Gentry inform Lyons she would return if he wished to talk. Lyons was reminded he needed to initiate contact. Subsequently, Lyons expressed a desire to talk, prompting Gentry to return to the holding cell. Trooper Overbey advised him of his Miranda rights using a question-and-answer format, which Lyons acknowledged he understood. He consented to a tape-recorded statement, where he confessed in detail to the killings and also provided a written statement.
After his arrest, Lyons attempted self-harm, leading to his placement on suicide watch and commitment to the Missouri Department of Mental Health (DMH). Following his indictment, the State sought a psychiatric evaluation, which the trial court granted despite defense objections. Two forensic examiners, Dr. Harry and Dr. Stacy, concluded that Lyons was not mentally competent to understand the proceedings or assist his defense due to severe depression, prompting the trial court to suspend criminal proceedings.
In November 1993, Dr. Holcomb evaluated Lyons and determined he had not regained competency. However, by May 30, 1994, Dr. Holcomb opined that Lyons was competent to stand trial if his attorney could establish a rapport with him. Dr. Holcomb noted Lyons wanted to go to court. In response to the State's motion to proceed to trial, defense counsel hired Dr. Johnson, who concluded Lyons was not competent. A competency hearing on February 23, 1995, saw Drs. Holcomb and Johnson testify in line with their evaluations. Ultimately, the trial court found Lyons competent to stand trial, ordering him to remain hospitalized until trial. Lyons subsequently moved to suppress his confession and statements made after his arrest.
In April 1996, a trial court held a hearing on Lyons's motion to suppress, which was ultimately overruled. On April 16, 1996, Dr. Harry informed Lyons's counsel that while he did not find Lyons incompetent to stand trial, he noted Lyons's mental health struggles and potential suicidal tendencies. Lyons expressed a desire to proceed to trial. Dr. Johnson, also on April 16, asserted that Lyons's mental illness did not impair his ability to understand the criminality of his actions at the time of the offenses. Competence was not raised again by Lyons or his counsel before the Missouri state courts.
Lyons's trial began on April 22, 1996, where evidence included his taped confession and witness testimony regarding the shootings. The jury found Lyons guilty of first-degree murder for killing Harris and Sparks, and involuntary manslaughter for killing Dontay. During the penalty phase, witnesses, including Dr. Johnson, discussed Lyons's longstanding depression but confirmed it did not affect his understanding of his crimes. The jury recommended the death penalty for Harris's murder, identifying three aggravating circumstances, while they could not agree on a punishment for Sparks's murder and suggested seven years for Dontay's death. The trial court sentenced Lyons to death for the murders and seven years for the manslaughter.
Lyons's convictions and sentence were affirmed by the Missouri Supreme Court. He later filed a pro se motion for post-conviction relief, which was denied and affirmed by the Supreme Court. Lyons then sought habeas relief under 28 U.S.C. § 2254, claiming eleven constitutional violations, but the district court denied the petition while allowing an appeal on two issues: mental incompetence at trial and the admissibility of his confession. The court expanded this to include the effectiveness of counsel concerning mental health expert testimony. Appeals are reviewed in habeas cases for clear factual error and de novo on legal conclusions.
To obtain habeas relief under 28 U.S.C. § 2254, an applicant must show that the state court's decision was either contrary to or an unreasonable application of clearly established federal law, or based on an unreasonable determination of facts from the state court record. A federal court cannot grant relief merely based on its independent judgment that the state court erred; the application must also be deemed unreasonable.
In the case of Lyons, he asserts that his conviction should be overturned due to a lack of mental competence to stand trial and argues that any procedural default on this claim should be excused because of his mental incompetence. He further claims that the trial court failed to reassess his competency after an initial determination made fourteen months prior. The State counters that Lyons defaulted on this claim by not presenting it in Missouri state courts and asserts that the trial court reasonably found him competent to stand trial.
The Due Process Clause prohibits prosecuting a defendant who is not competent to stand trial, requiring the defendant to understand the proceedings and assist in their defense. Competence must be continually monitored throughout the trial, considering factors such as irrational behavior, demeanor, and prior medical opinions. While an attorney's express doubt about the defendant's competence can be considered, it is insufficient on its own to establish incompetence. Failure to raise a claim in state post-conviction proceedings leads to procedural default, and competency issues can also be barred procedurally. Despite Lyons's claims of incompetence, it is noted that his counsel was present and had the responsibility to monitor his mental fitness during the trial.
Lyons has procedurally defaulted on his trial competency claim, and even if not defaulted, he would not succeed on the merits. The due process clause requires defendants to prove their own incompetence, and Lyons failed to meet the burden of persuasion regarding his competency to stand trial. The state court’s finding of competency is presumed correct, supported by Dr. Holcomb’s report and testimony, which indicated that Lyons was competent. Lyons did not provide contrary evidence at the competency hearing or subsequent proceedings. His assertion that Dr. Harry found him incompetent is unsubstantiated, as he did not call Dr. Harry to testify at critical times. The trial court did not revisit the competency issue during the trial, and Lyons's counsel did not raise the matter again until this collateral proceeding.
Regarding ineffective assistance of counsel, Lyons argues that his attorneys were ineffective for not calling state hospital doctors to testify about his mental capacity at the time of the shootings. The State counters that trial counsel made a strategic decision to use a privately retained expert instead of state doctors, avoiding potential unfavorable reports. By trial time, the private expert did not support Lyons's claim of diminished capacity. To succeed on an ineffective assistance claim, Lyons must show his counsel's performance was deficient and that he suffered prejudice from it. Reasonable performance requires thorough investigation and consideration of viable defense theories, while prejudice is established if there’s a reasonable probability that the outcome would have been different absent counsel's errors.
Counsel is presumed to have provided adequate assistance and made reasonable professional judgments, but strategic choices based on insufficient investigation lack deference. In evaluating a conviction challenge, the critical question is whether a reasonable probability exists that the defendant would not have been convicted had counsel performed effectively. In the context of a death sentence, the focus shifts to whether the jury would have reached a different conclusion regarding mitigating circumstances absent counsel's deficiencies.
Lyons has not demonstrated that his counsel’s performance was deficient. The decision to forgo a diminished capacity defense was reasonable given the evidence at hand. Counsel strategically chose not to rely on State-employed doctors, opting instead to hire a private doctor to maintain control over the competency issue and protect against unfavorable findings being disclosed to the prosecution. Dr. Johnson, retained by the defense, conducted an extensive evaluation of Lyons but concluded that Lyons's mental illness did not impair his ability to understand his actions or conform to the law.
The lead attorney testified to a deliberate choice to avoid introducing mental health issues during the guilt phase, believing the jury would reject the argument that major depression mitigated Lyons's capacity to deliberate murder. This decision stemmed from the attorney's concerns about his expertise in mental health defenses and the nature of the crime, which he felt indicated rage rather than a lack of deliberation. Lyons's assertion that counsel abandoned a valid defense due to inadequate preparation is unfounded; rather, the strategy evolved when Dr. Johnson was unwilling to support an incapacity argument. Additionally, the failure to call other doctors as witnesses was not indicative of ineffective assistance.
The state post-conviction court deemed Dr. Harry's testimony ineffective, supported by evidence indicating Lyons was capable of deliberation at the time of the crimes. Dr. Harry acknowledged uncertainty about the distinction between forming intent and reflecting coolly and conceded that Lyons exhibited premeditated thoughts about the murders, demonstrated by his statements prior to the events. Furthermore, Dr. Harry's earlier communication to counsel did not declare Lyons incompetent but mentioned his struggles and potential suicidal tendencies, lacking significant legal weight. This aligns with precedent indicating that mental illness does not equate to trial incompetency. Dr. Holcomb corroborated that Lyons displayed a thought process regarding the murders, suggesting he was competent to stand trial. Dr. Altomari also found Lyons aware of his intentions and capable of distinguishing right from wrong. Collectively, the evidence suggested a diminished capacity defense would likely fail, justifying trial counsel's decision not to pursue it as reasonable under Strickland's standard for effective assistance.
Regarding Lyons's confession, he argued the district court correctly found him incompetent at the time of the confession and that the State did not demonstrate a knowing waiver of rights. However, the State contended that Lyons's actions indicated competence and voluntary waiver. The Missouri Supreme Court previously ruled that Lyons's confession was voluntary and that he was adequately informed of his Miranda rights, asserting no evidence contradicted this understanding during interrogation. The court concluded that the officers provided thorough advisement of his rights, reinforcing the argument for the confession’s admissibility.
The district court acknowledged the possibility that Lyons's confession was not made knowingly and intelligently but concluded that the Missouri Supreme Court's decision regarding the admissibility of the confession was not unreasonable. Evidence indicated Lyons's competence, including his premeditated actions related to the murders, his instructions to associates to evade police, and his coherent behavior post-arrest, such as requesting a lawyer and discussing the incident with police. The Missouri Supreme Court found no error in denying the suppression of Lyons's statements, asserting that a defendant does not have a constitutional right to confess only when fully rational. Even if the confession was improperly admitted, the court concluded that any error was harmless due to the overwhelming independent evidence against Lyons, such as eyewitness accounts and physical evidence. The district court's denial of habeas relief was thus affirmed.
