The Arkansas Supreme Court recently upheld the conviction and life sentence of a Bradley County man convicted of the February 2017 shooting death of his father and the 10-year sentence for possession of a firearm.
Alfonzo Hampton, then 35, of Johnsville, drove to the Warren Police Department carrying his father’s body in the trunk of a vehicle. He told officers he had killed his father and the body was in the trunk of his car. He also handed one of the officers a gun.
Hampton’s father, Fred Hampton died as a result of two gunshot wounds to the head.
The question before the Supreme Court was not whether Alfonzon Hampton killed his father, but whether the Bradley County Circuit Court made an error in determining that Hampton was competent to stand trial. Medical professionals were not in agreement in their opinions on whether Hampton was fit to stand trial.
After Alfonzo Hampton was charged with first-degree murder and possession of a firearm, he requested a competency determination. Circuit Court Judge Sam Pope in August 2017 ordered that Hampton be evaluated to determine his fitness to proceed to trial.
Dr. Lacey Willett Matthews, a forensic psychologist at the Arkansas State Hospital, determined that Hampton was not fit to proceed to trial. Subsequently, Hampton was committed to the Arkansas State Hospital where he underwent restoration proceedings through an outpatient restoration program.
Later, Dr. Julie Wood, a forensic psychologist, filed an evaluation report saying Hampton “did not lack the capacity to understand the proceedings against him and did not lack the capacity to assist effectively in his own defense.”
Hampton’s attorney asked the circuit court to delay ruling on Hampton’s fitness until he could obtain an independent evaluation. Hampton was then evaluated by Dr. Raymond K. Molden, a forensic psychiatrist. It was Dr. Molden’s opinion that Hampton understood the proceedings against him but lacked the capacity to effectively assist his attorney.
In August 2019 circuit court again held a hearing on Hampton’s fitness to proceed, Dr. Wood testified that Hampton is schizophrenic and has a long history of schizophrenia and acknowledged that Hampton had previously been found unfit to proceed to trial. Although Dr. Wood was not provided with information on the medications he was taking at the time of his evaluation, Hampton informed her that he was taking routine medications in the morning and evening and that they were helping him.
Dr. Wood testified that Hampton passed the Georgia Core Competency Test (GCCT), a fitness-to-proceed examination. She discussed his restoration proceedings and acknowledged that the counselor who conducted those proceedings felt that Hampton was unfit and would not become fit to proceed. However, Dr. Wood testified that the counselor was not authorized or trained to make that call.
Dr. Wood testified that she evaluated whether Hampton had the rational capacity to make decisions about his future and whether he understood the facts related to the courtroom and to the crime. She testified that on the day of her evaluation, Hampton behaved appropriately and communicated sufficiently. Dr. Wood stated that with patience, he could testify on his own behalf.
Dr. Wood reported that she could understand Hampton 95 percent of the time and it was her opinion that his thought process was logical. He did not display hallucinations, delusions, obsessions, compulsions, or phobias. He denied depression and anxiety. Dr. Wood’s conclusion about Hampton’s thought process was based on her hour-and-forty-five-minute interview with Hampton, during which he gave an entire history on himself and answered her questions.
Dr. Wood said it was her opinion that Hampton understood his plea options and the benefits and consequences of a plea bargain. She based that opinion on his responses to questions on whether he knew the meaning of guilty and not guilty, whether he knew that he could plead not guilty despite his behavior, and whether he understood and could identify the benefits and consequences of a plea bargain. Hampton told Dr. Wood that he would tell his lawyer the truth of everything that happened on the date of the crime and was willing to work with his attorney.
Dr. Wood did not discuss specific defenses with Hampton because that required “that’s a higher level understanding that we don’t expect our average inmate to understand.” Dr. Wood testified that Hampton was capable, on the date of the evaluation, of making reasonable choices about his defense. With proper medication, she believed that Hampton was fit to proceed to trial.
Dr. Molden then testified about his November 2018 evaluation of Hampton. In assessing Hampton’s fitness to proceed, Dr. Molden evaluated whether Hampton understood the legal proceedings against him, both rationally and factually, and whether he had the ability to effectively assist his attorney. Dr. Molden also administered the GCCT and reported that Hampton passed with a score of 88 out of 100. Dr. Molden stated that Hampton understood the proceedings against him.
Dr. Molden concluded, however, that Hampton was not fit to proceed because he could not assist in his own defense. Specifically, Dr. Molden discussed Hampton’s long history of schizophrenia and his opinion that little progress was made during restoration proceedings. Dr. Molden believed that Hampton lacked the ability to effectively engage or to disclose to his attorney pertinent facts, events, or his state of mind at the time of the crime.
Dr. Molden also testified about Hampton’s lack of depth or detail when answering questions and believed that Hampton was unable to engage in a reasoned choice of legal strategies. Dr. Molden opined that Hampton’s answers to non-case-related vignettes showed some impairment in his reasoning ability to consider information that might be relevant to present to his defense attorney. He opined that although Hampton could verbalize a choice, that choice did not seem to have a rational understanding behind it. Dr. Molden testified that during his two-hour interview with Hampton, he appeared apathetic, paranoid, guarded, and not forthcoming. Dr. Molden believed Hampton’s fitness could be restored in another setting with a change in medication.
Following Dr. Molden’s testimony, the Dr. Wood was recalled to the stand. She explained that apathy occurs outside of schizophrenia or any mental illness. She opined that probably 90 percent of inmates develop a sense of apathy toward the legal system because of their past experiences. She reiterated her belief that Hampton could effectively assist his attorney.
In an August 26, 2019 order, Circuit Court Judge Sam Pope found that Hampton was fit to proceed and ordered him to trial.
A Bradley County Circuit Court jury subsequently found Hampton guilty of first-degree murder and possession of a firearm by certain persons. He was sentenced to life imprisonment for the murder conviction and ten years’ imprisonment for the firearm conviction, to be served consecutively.
In his sole point on appeal, Hampton argued that the circuit court erred in determining that he was fit to proceed to trial because his schizophrenia prevented him from effectively assisting in his own defense.
The conviction of an accused person while he or she is legally incompetent violates due process. The test for competency on appeal is whether substantial evidence supports the circuit court’s finding, according to the Arkansas Supreme Court.
“We have stated that, following a circuit court’s ruling on competency to stand trial, we will not attempt to weigh the evidence or pass on the credibility of witnesses when the medical reports conflict with each other,” Arkansas Supreme Court Chief Justice John Dan Kemp wrote. “With dueling medical experts, we have explained that the trier of fact observes the witnesses firsthand, sees their demeanor and responsiveness in answering questions, and is in the best position to determine which is the more credible witness.”
Hampton argued that Dr. Molden’s opinion should have been given more weight than Dr. Wood’s because his testimony was more thorough on Hampton’s ability to convey information to his attorney and to rationally decide whether to plead guilty or go to trial.
“We will not reweigh the credibility of these conflicting medical experts,” Kemp wrote. “Dr. Wood provided detailed testimony on how she reached her conclusion that Hampton could effectively assist his attorney, which included Hampton’s interview, his performance on the GCCT, and her review of his extensive medical history. Dr. Wood’s report and testimony provided substantial evidence to support the circuit court’s ruling. … Thus, we hold that the circuit court did not err in determining that Hampton was fit to stand trial, and we affirm Hampton’s convictions and sentences.”