The Tennessee Supreme Court has held that advocates for convicted serial killer Paul Dennis Reid may not continue appealing his convictions in state court against his wishes, despite claims he is not competent to abandon his appeals.
In 1997, Mr. Reid committed three armed robberies in Nashville and Clarksville during which he killed seven persons. Mr. Reid received seven death sentences, after juries in Nashville and Clarksville convicted him of especially aggravated robbery and premeditated first degree murder.
In 2003, just before his first scheduled execution date, Mr. Reid filed a petition for post-conviction relief, seeking a new trial on three of his robbery and murder convictions. Later, he changed his mind about seeking relief and insisted that he had resigned himself to being executed and that he no longer desired to seek new trials. Despite Mr. Reid’s decision, his appointed attorneys and his sister filed petitions on his behalf in all of his cases. They asserted that Mr. Reid lacked the mental competency to abandon his post-conviction appeals.
The courts in Nashville and Clarksville conducted separate hearings in 2008. Both courts decided that Mr. Reid’s sister and his lawyers had failed to prove that Mr. Reid was not mentally competent to decide whether to pursue new trials. Thus, they dismissed the petitions seeking post-conviction relief that had been filed on Mr. Reid’s behalf by his sister and his lawyers. The Court of Criminal Appeals affirmed these decisions in 2011.
In a unanimous opinion, the Supreme Court affirmed the decisions of the trial courts and the Court of Criminal Appeals. Despite the evidence of Mr. Reid’s brain damage and mental health issues, the Court agreed with the lower courts that his sister and attorneys failed to present clear and convincing evidence that he is incompetent to make his own legal decisions. The Court’s opinion also clarifies the standards and procedures to be used to determine mental competency in post-conviction cases.