McManus v. Neal, No. 12-2001 (7th Cir. 2015)
Annotate this CaseMcManus, on trial for murdering his wife and young daughters, decompensated during testimony. He had several panic attacks; his symptoms required two trips to the emergency room. He was treated with a combination of psychotropic drugs—including one that knocks out memory—and an opioid painkiller. He remained on mind-altering medications for the duration of the trial. The judge never ordered a competency evaluation, but focused on getting McManus “fixed up” enough to complete the trial, and sentenced him to death. The Indiana Supreme Court affirmed on direct appeal, but on post-conviction review the trial judge found McManus intellectually disabled and ineligible for the death penalty (IND. CODE 35-36-9-6). The Indiana Supreme Court disagreed and reimposed the death sentence. McManus sought federal habeas review. The district court denied relief. The Seventh Circuit reversed. While McManus is not entitled to habeas relief on his claim of categorical ineligibility for the death penalty, the powerful effect of the medications alone created substantial doubt about his fitness for trial. The approach taken by the trial judge failed to apply the correct legal framework for competency questions. The Indiana Supreme Court recited the correct legal standard but did not actually apply it.
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