The Supreme Judicial Court ruled today that Donald Chatman, conviced of shooting his mother to death in 2000, should get a hearing to provide what he says is proof that he deserves a new trial because he was incompetent to stand trial in the first place due to mental illness.
Chatman was convicted of shooting his mother, with whom he did not get along, in his aunt's Roxbury apartment on Feb. 10, 2000. Although police never found the gun, they did find his bloody fingerprint on the wall of his bedroom, as well as his mother's blood on "his sneaker, his clothes, the bottom edge of his bedroom door, his mattress, and the shower curtain liner in the bathtub."
The state's highest court said Chatman might suffer from a particular form of mental illness that might not show up under cursory examination in a trial setting - "a schizoaffective disorder with prominent paranoid delusions" - and that while he may have failed initially to provide sufficient evidence of that diagnosis, prosecutors may not have provided enough evidence to prove that he was competent to stand trial.
The Superior Court judge hearing Chatman's request for a new trial - who also presided over his original trial - denied his request for an "evidentiary hearing," saying he failed to prove he was insane enough even for a detailed hearing. The Supreme Judicial Court, however, said Chatman had provided enough expert evidence to at least warrant a new hearing:
We are satisfied that in this unusual case the issue is serious and the defendant has made an adequate showing to warrant an evidentiary hearing. He has made an adequate showing that he had a mental illness that would have concealed itself to the judge and counsel. He also made an adequate showing that the Commonwealth might not have proved he was competent. This is particularly so where the Commonwealth offered no expert evidence that the defendant was competent at the time of trial. The only evidence that the defendant was competent appears to be the judge's reference to three conferences between the defendant and counsel during trial (about which the record reveals little), and her own observations of the trial. In contrast, Dr. Leavitt, whose reports on the defendant's competence in 2010 appear to have been credited by the judge, made a diagnosis of long-standing mental illness virtually identical to that of Dr. Joss. She opined that the defendant was not able to assist appellate counsel at a full evidentiary hearing on the motion for a new trial. Like Dr. Joss, Dr. Leavitt determined that the defendant's inability to trust his lawyer was a significant factor in her reports. Although the opinions of Drs. Joss and Leavitt regarding the defendant's competence addressed very different times and proceedings, the similarities and parallels raise concerns that are sufficiently serious to warrant an evidentiary hearing on the defendant's motion for a new trial. ...
At the hearing, testimony of trial counsel would be desirable, particularly where the Commonwealth has elected to offer no expert testimony. Trial counsel may be able to provide relevant evidence as to the defendant's ability to understand the nature of the case against him and his ability to assist in the defense, as well as how the defendant helped shape the defense, if at all. We express no view about what the outcome of the hearing should be, but because of the confusion at the hearing on the motion for a new trial as to the burden of proof, we repeat our earlier explication that the burden is on the defendant to establish by a preponderance of the evidence that the Commonwealth would not have been able to prove he was competent to stand trial.