Charles Laverne Singleton v. Larry Norris, Director, Arkansas Department of Correction
Docket: 95-3032
Court: Court of Appeals for the Eighth Circuit; March 12, 1997; Federal Appellate Court
Charles Laverne Singleton appeals the dismissal of his habeas corpus petition by the district court. Singleton was sentenced to death in 1979 for capital murder after stabbing a storekeeper during a robbery, with his conviction affirmed by the Arkansas Supreme Court. In 1982, his petition under Rule 37 of the Arkansas Rules of Criminal Procedure was denied. Singleton later filed a habeas corpus petition in federal court, which initially vacated the death penalty based on the double counting prohibition established in Collins v. Lockhart. However, after the U.S. Supreme Court's decision in Lowenfield v. Phelps, which implicitly overruled Collins, the Eighth Circuit reversed the district court's ruling and reinstated the death sentence while affirming the denial of Singleton's guilt phase claims.
Subsequently, on remand, the district court dismissed Singleton's remaining claims in 1990, an outcome that was upheld by the Eighth Circuit in 1992. In December 1992, Singleton filed a new action in state court, claiming he was incompetent to be executed and lacked the procedural protections outlined in Ford v. Wainwright. While this action was ongoing, an execution date was set for Singleton, coinciding with the U.S. Supreme Court's consideration of the double counting issue in Tennessee v. Middlebrooks.
Singleton filed a petition asserting claims of double counting and violations under Ford v. Wainwright. The district court held the petition in abeyance pending a decision in Tennessee v. Middlebrooks. The Supreme Court of Arkansas later rejected Singleton's Ford claims. The district court conducted hearings regarding Singleton's competency for execution and his claim of actual innocence. It determined that Singleton was competent due to his voluntary antipsychotic medication intake and dismissed both his double counting and actual innocence claims, leading to Singleton's appeal focused on the denial of his double counting claim.
Singleton argued for reconsideration of precedent regarding the Arkansas capital murder statute's constitutional narrowing function, but the court stated it could not overturn established circuit law. Following this, an Arkansas Supreme Court ruling in Brown v. State clarified that second-degree murder is not a lesser included offense of capital felony murder. The court allowed supplemental briefs to assess Brown's impact on the narrowing function of the capital murder statute but ultimately concluded that Brown did not undermine the narrowing requirement established in previous cases.
Singleton did not claim current incompetency and thus did not challenge the district court's ruling on that issue. The court affirmed the district court's dismissal of the habeas corpus petition.
Circuit Judge Heaney expresses his agreement with the outcome of the case while highlighting the double-counting issue raised by Singleton. He notes the lack of distinction between Singleton's claim and previous court decisions, asserting that the Eighth Amendment prohibits using pecuniary-gain motives as the sole aggravating circumstance for death sentences in robbery-murder cases. He acknowledges the limitations of the court's current review capabilities and the unresolved nature of executing individuals whose competency is chemically induced. Although Singleton's competency under medication is deemed sufficient by the district court, Heaney emphasizes that this does not preclude future claims regarding his competence for execution.
Heaney also voices his opposition to the death penalty, arguing it is arbitrary and capricious, influenced by factors such as the political motivations of prosecutors, the defendant's socioeconomic status, and the quality of legal representation. He stresses how a defendant's economic status significantly impacts their legal defense, with wealth allowing access to competent counsel while indigent defendants often receive inadequate representation, as exemplified by Singleton's case, where his trial counsel was minimally compensated. This disparity, Heaney contends, undermines the due process principles fundamental to the justice system.
Adequate funding is crucial for qualified criminal defense lawyers to build credible defenses and present mitigating factors against the death penalty; however, poor defendants often receive representation from inexperienced lawyers, resulting in inadequate legal defense. This issue extends to appellate and post-conviction stages for indigent defendants. Racial bias further exacerbates the arbitrariness of the death penalty system, with studies indicating that individuals who kill white victims face harsher sentences compared to those who kill black victims. The American Bar Association has cited systematic racial discrimination in capital sentencing as a reason to seek a moratorium on executions until fair safeguards are implemented. Even sophisticated death penalty statutes are influenced by societal biases, raising concerns about the fairness of capital punishment. Recent changes to federal habeas corpus rules have complicated the adjudication of legitimate constitutional claims for those sentenced to death, leading to many claims remaining unaddressed. The author expresses a personal belief that the capital punishment system in the U.S. is irrational, arbitrary, and unfair, and doubts that it can ever be administered consistently and rationally. The document also details specific legislative changes regarding attorney fees for indigent defense in Arkansas and highlights the systemic underfunding and challenges faced by attorneys representing poor defendants, resulting in a cycle of inadequate legal representation.
