Hood v. State
| Docket Number: | 2017-CP-00165-COA Linked Case(s): 2017-CT-00165-SCT ; 2017-CP-00165-COA |
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| Court of Appeals: |
Opinion Link Opinion Date: 02-18-2020 Opinion Author: McDonald, J. Holding: Affirmed. |
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| Additional Case Information: |
Topic: Post-conviction relief - Due process rights - Competency hearing - URCCC 9.06 - Mental evaluation Judge(s) Concurring: Barnes, C.J., Carlton and JWilson, P.JJ., Greenlee, Tindell, Lawrence, McCarty and CWilson, JJ. Non Participating Judge(s): Westbrooks, J. Procedural History: PCR Nature of the Case: PCR |
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| Trial Court: |
Date of Trial Judgment: 04-26-2017 Appealed from: YAZOO COUNTY CIRCUIT COURT Judge: HON. JANNIE M. LEWIS-BLACKMON Disposition: Convicted of exploitation of children and sentenced as a habitual offender to serve twenty years without eligiblity for parole. Sentence was affirmed by the Mississippi Supreme Court and motion for rehearing was denied. Hood filed motions for PCR, and the supreme court granted Hood permission to proceed to trial court to pursue his due process claim based on the lack of a competency hearing. Hood filed PCR motion in trial court, which was denied. Case Number: 26-0119 |
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| Consolidated: 2008-KA-00099-SCT | ||
| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Ronald Hood a/k/a Ronald J. Hood |
RONALD HOOD (PRO SE) |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: LAURA HOGAN TEDDER | ||
Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Post-conviction relief - Due process rights - Competency hearing - URCCC 9.06 - Mental evaluation |
| Summary of the Facts: | Ronald Hood was convicted of the crime of exploitation of children and sentenced as a habitual offender to twenty years. He appealed, and the Mississippi Supreme Court affirmed. Hood then filed several motions for post-conviction relief. In 2016, the Supreme Court granted Hood permission to proceed in the trial court to pursue his due process claim based upon the lack of a competency hearing. Hood filed his PCR motion in the trial court, which denied the motion. Hood appeals. |
| Summary of Opinion Analysis: | Hood argues that his due process rights were violated because since his conviction and sentence, the Supreme Court has mandated in Sanders v. State, 9 So. 3d 1132 (Miss. 2009), that when a court orders a psychiatric evaluation, it is an error for it to not hold a competency hearing. Hood is correct that Sanders interpreted URCCC 9.06 to mandate a competency hearing in every case when the court orders that a mental evaluation be conducted. However, the Court has held that Sanders is not to be applied retroactively. Thus, Sanders does not have an effect on Hood’s 2007 conviction. Hood also argues that Rule 9.06 provides that the trial court must order a mental evaluation and conduct a hearing if the court has reasonable grounds to believe the defendant is incompetent. Hood was given a mental evaluation by Dr. Lott, who concluded that Hood did not appear to need further testing or psychiatric treatment. Dr. Lott’s report was made a part of the record and the court relied upon it when concluding that Hood was competent to stand trial. Hood failed to provide the trial court with information that would have reasonably raised a doubt about his competence and alerted the court of the possibility that he could neither understand the proceedings, nor rationally aid his attorney in his defense. Therefore, this issue is without merit. |
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