Maggio v. Fulford
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462 U.S. 111 (1983)
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U.S. Supreme Court
Maggio v. Fulford, 462 U.S. 111 (1983)
Maggio v. Fulford
Decided June 6, 1983
462 U.S. 111
After respondent's murder conviction was affirmed by the Louisiana Supreme Court, and after he had exhausted state postconviction remedies, he was denied habeas corpus relief in Federal District Court. The Court of Appeals reversed, apparently holding that, under 28 U.S.C. § 2254(d)(8), the state trial court's determination that respondent was competent to stand trial was not "fairly supported by the record." The state court had denied respondent's motion for appointment of a competency commission, which motion was filed on the morning of trial and was supported solely by a psychiatrist's testimony -- based upon a brief prison cell interview on the preceding day -- that respondent had paranoid delusions that rendered him incompetent to stand trial, respondent having said that he was withholding from his counsel the names of alibi witnesses for fear that they would be arrested and prevented from testifying.
Held: The Court of Appeals erroneously substituted its own judgment as to the credibility of witnesses for that of the Louisiana courts -- a prerogative which 28 U.S.C. § 2264 does not allow it. The trial judge's conclusion as to respondent's competency was "fairly supported by the record," which showed that the judge based his conclusion on, inter alia, his observation of respondent's conduct both before and during trial; his inferences regarding the fact that respondent's alleged refusal to disclose his alibi witnesses either never occurred or was remedied; and his conclusion that respondent's surprise, 11th-hour motion for appointment of a competency commission was merely a subterfuge to attempt to obtain a severance to avoid being tried with codefendants.
Certiorari granted; 692 F.2d 354, reversed.