State of Louisiana v. LaDerrick Campbell

Summary

The Louisiana Supreme Court reviews LaDerrick Campbell’s convictions and death sentence for the first-degree murder of Kathy Parker during an armed robbery. The court addresses, among other issues, Campbell’s self-representation, mental health and competency claims, the evidentiary record, and capital-sentencing issues, and affirms the conviction and sentence.

Holdings

1. The record did not show a reasonable likelihood that Campbell qualified as mentally retarded, and a remand for an evidentiary hearing was unwarranted.
2. Roper v. Simmons establishes a categorical age threshold based on chronological age, not alleged mental age; because Campbell was eighteen when he committed the murder, he was not covered by Roper's exemption.
3. The trial court did not abuse its discretion in denying defense counsel's request for a sanity commission or in declining to order a competency evaluation on its own motion.
4. The trial court properly permitted Campbell to waive counsel and represent himself during the remainder of voir dire and the guilt phase.
5. The alleged hearsay and Confrontation Clause errors were not properly preserved because Campbell did not contemporaneously object.

Questions Presented

1. Whether the record established reasonable grounds to conclude that Campbell was mentally retarded and constitutionally exempt from execution under Atkins v. Virginia and Louisiana law.
2. Whether Campbell's alleged mental age rendered him ineligible for the death penalty under Roper v. Simmons.
3. Whether the trial court abused its discretion by denying a request for a sanity commission or failing to order a competency examination on its own motion.
4. Whether Campbell was competent to waive counsel and whether the trial court's Faretta colloquies adequately established a knowing, intelligent, voluntary, and unequivocal waiver.
5. Whether alleged hearsay and Confrontation Clause errors concerning a codefendant's statement were preserved for appellate review.

Disposition

affirmed