State of Indiana v. Paul M. McManus

Summary

The Supreme Court of Indiana reversed a post-conviction court's determination that Paul McManus was mentally retarded and its reduction of his death sentence to life without parole. The court held that McManus's post-Atkins mental-retardation claim was properly before the post-conviction court, but that he failed to establish significantly subaverage intellectual functioning or substantial impairment of adaptive behavior. The court also rejected or declined to disturb claims concerning expert testimony, competency, and ineffective assistance of counsel.

Holdings

1. McManus's mental-retardation claim was properly before the post-conviction court because the claim did not ripen until Pruitt modified Indiana's statutory scheme to comply with Atkins.
2. McManus did not prove significantly subaverage intellectual functioning, and the post-conviction court's contrary finding was clearly erroneous.
3. McManus did not prove substantial impairment of adaptive behavior because the ABAS II primary-domain scores did not show impairment in the conceptual, social, or practical domains, and his work and daily-life functioning further undermined the claim.
4. The post-conviction court's admission of the testimony and reports did not warrant reversal because the State did not establish specific resulting prejudice.
5. McManus's claims that he was incompetent to stand trial were barred by res judicata because competency had been addressed on direct appeal.
6. McManus failed to establish ineffective assistance because counsel adequately litigated competency and presented substantial, non-deficient mitigation evidence.
7. McManus did not establish an actual conflict of interest that adversely affected counsel's performance.

Questions Presented

1. Whether McManus's Atkins mental-retardation claim was preserved despite his failure to use Indiana's preexisting statutory procedure.
2. Whether McManus proved significantly subaverage intellectual functioning and substantial impairment of adaptive behavior under Indiana law.
3. Whether the post-conviction court erred by admitting testimony and reports from Dr. Haskins and Dr. Olvera despite alleged discovery and witness-list violations.
4. Whether McManus's competency claims were barred by res judicata.
5. Whether trial counsel was ineffective for failing to adequately litigate competency and investigate or present mitigating evidence.
6. Whether trial counsel operated under an actual conflict of interest.

Disposition

reversed