McWilliams v. Dunn

One month after the United States Supreme Court’s decision in Ake v. Oklahoma, Alabama prosecuted James McWilliams (defendant) for rape and murder. McWilliams matched Ake’s profile: an indigent criminal defendant whose conduct might have been affected by mental illness. State-appointed psychiatrists examined McWilliams and ruled out McWilliams’s mental condition as a factor to be considered during the guilt phase of McWilliams’s trial. A jury found McWilliams guilty and recommended the death penalty. During the trial’s sentencing phase, the court granted defense motions to subpoena McWilliams’s prison hospital records and for a more comprehensive psychiatric examination, which was carried out by Dr. John Goff, a state-employed psychiatrist. Dr. Goff’s report, submitted two days before McWilliams’s sentencing hearing, indicated that McWilliams’s psychotic symptoms, though exaggerated, were real. McWilliams’s prison hospital records, which arrived only hours before the sentencing hearing, showed that McWilliams was receiving a variety of psychotropic medications. Defense counsel had no psychiatric training and asked for a continuance sufficient to permit consultation with qualified psychiatric professionals. The trial court adjourned the proceedings for just a few hours, after which the hearing resumed and the court sentenced McWilliams to death. An Alabama appeals court affirmed the sentence. After spending decades on death row, McWilliams filed a habeas corpus petition against Jefferson Dunn, Alabama’s commissioner of corrections, alleging that McWilliams had been deprived of his full Ake rights. A magistrate judge denied the petition and was affirmed by the Eleventh Circuit. The Supreme Court granted certiorari to hear McWilliams’s appeal.