Watkins v. DeAngelo-Kipp, No. 15-2445 (6th Cir. 2017)
Annotate this CaseBefore his jury trial on charges of murder, Watkins submitted four times to psychiatric evaluation. Though the first evaluator found him incompetent, subsequent evaluators found him competent and criminally responsible for his actions. Despite his bizarre behavior during trial, including exhibiting paranoid beliefs and urinating on a television screen, defense counsel did not request a fifth psychiatric evaluation. A jury found Watkins guilty. Nearly four years after filing a timely habeas petition alleging ineffective assistance of counsel for “failure to investigate and raise a defense,” Watkins filed an amended petition arguing ineffective assistance of counsel for failure to request another psychiatric evaluation after Watkins’ conduct during trial. The Sixth Circuit reversed the district court’s grant of habeas relief. Watkins cannot establish that his amended petition relates back to his original petition or that he is entitled to equitable tolling; the petition was, therefore, untimely.
This opinion or order relates to an opinion or order originally issued on January 10, 2017.
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