Court Overturns Death Sentence for Failure to Introduce Defendant's Mental Health History for Mitigation Purposes

Subhash Chandra; Clarence Watson

Defense Counsel Failed to Investigate and Introduce Evidence of the Defendant's Mental Health History During the Penalty Phase

In Saranchak v. Secretary, Pennsylvania Dept. of Corrections, 802 F.3d 579 (3d Cir. 2015), the Third Circuit Court of Appeals overturned a death sentence on appeal from the district court's action on a petition for writ of habeas corpus claiming ineffective assistance of counsel during the guilt and penalty phases of trial. Although the circuit court found no grounds for ineffective assistance of counsel during the trial's guilt phase, they found that trial counsel's failure to investigate and introduce mitigating factors, including a dysfunctional childhood history and mental health history, amounted to ineffective assistance of counsel during the penalty phase. Accordingly, the defendant's conviction was upheld, but his death sentence was overturned.

Facts of the Case

On October 15, 1993, Daniel Saranchak was intoxicated when he and a friend traveled to Saranchak's grandmother's home, where Mr. Saranchak killed his uncle and grandmother. During police interrogation, Mr. Saranchak assumed a militaristic posture and behaved as if interacting with drill sergeants. He reported being present at his grandmother's home on a military mission and claimed that information about his grandmother's death was classified. He admitted to shooting his uncle. While incarcerated pending trial, Mr. Saranchak met with a child services caseworker regarding his minor children, and he provided incriminating details regarding both killings.

Mr. Saranchak's attorney requested a court-appointed psychiatrist to evaluate his competency to stand trial and mental capacity to form the specific intent to kill at the time of the crime. The trial court granted the motion regarding the competency examination, but did not order the examination for diminished capacity. Mr. Saranchak was found competent to stand trial, and his defense attorney later testified that he did not seek the diminished-capacity evaluation, because nothing in the competency report indicated that further examination would be helpful.

Mr. Saranchak entered a guilty plea to murder generally, but contested the degree of guilt at a nonjury trial. He presented a diminished-capacity defense, but his attorney did not present expert testimony. Instead, he presented testimony from family and friends regarding Mr. Saranchak's excessive consumption of alcohol on the night of the murders to support the diminished-capacity claim. Mr. Saranchak was found guilty of two counts of first-degree murder. During the penalty phase, a jury returned the death sentence.

On appeal, Mr. Saranchak challenged his conviction on the grounds of ineffective assistance of counsel related to the presentation of the diminished-capacity defense and mitigation evidence. The Pennsylvania Supreme Court affirmed his conviction and sentence. Mr. Saranchak then sought state postconviction relief pursuant to the Pennsylvania Post-conviction Relief Act (PCRA), by asserting that his attorney was ineffective. He was denied relief.

Mr. Saranchak then petitioned for habeas corpus in district court by arguing ineffectiveness of counsel. The district court granted relief on the grounds that his counsel had failed to investigate and present evidence supporting a diminished-capacity defense and had neglected to argue suppression concerns related to Mr. Saranchak's confessions. The district court did not resolve the question of ineffectiveness of counsel during the penalty phase. The Commonwealth appealed, and the Third Circuit Court reversed and remanded the case. On remand, the district court again denied relief.

On second appeal to the Third Circuit Court, Mr. Saranchak renewed his argument of ineffectiveness of counsel during the guilt phase for failure to present mental health evidence to suppress his confession and to support his diminished-capacity claim. He also argued ineffectiveness of counsel during the penalty phase based on his attorney's failure to introduce mental health evidence and dysfunctional family dynamics as mitigating circumstances. Mr. Saranchak's attorney testified that he did not investigate such evidence because the defendant and his family did not disclose Mr. Saranchak's mental health history.

Ruling and Reasoning

The Third Circuit Court ruled that Mr. Saranchak's defense was not prejudiced during the guilt phase by his attorney's failure to present his mental health history for his diminished-capacity claim or to suppress his confession to police. The court reasoned that other evidence, including his incriminating statements to a caseworker and his accomplice's testimony, established such compelling evidence of his intent and motive at the time of the crime that it would have outweighed any expert mental health testimony. Accordingly, the first-degree murder convictions were upheld.

However, the Third Circuit Court agreed that Mr. Saranchak was harmed by his attorney's failure to investigate and present evidence of his mental health history as a mitigating factor during the penalty phase. The court explained the twofold test for establishing ineffective assistance of counsel: that counsel's performance fell below an objective standard of reasonableness based on prevailing professional norms in the factual context of a particular case and that counsel's conduct prejudiced the defense. The court found that during the penalty phase, Mr. Saranchak's attorney unreasonably erred by not further investigating Mr. Saranchak's mental health history.

The circuit court rejected counsel's argument, and the Pennsylvania Supreme Court's earlier finding that counsel did not pursue evidence of Mr. Saranchak's psychiatric history because counsel was not privy to that information. Defense counsel asserted that Mr. Saranchak and his family did not inform him of Mr. Saranchak's problematic psychological history. However, the circuit court found that other sources beyond Mr. Saranchak and his family, including the competency evaluation that noted a prior psychiatric hospitalization and suicide attempt and Mr. Saranchak's abnormal behavior during his confession to police, indicated further need for investigation. The court found that counsel's reliance on a limited court-appointed competency-to-stand-trial evaluation and counsel's failure to obtain Mr. Saranchak's psychiatric hospitalization records fell below objective standards of reasonableness.

The circuit court also found that counsel's failure to investigate and present Mr. Saranchak's mental health history during the penalty phase prejudiced Mr. Saranchak's defense. Under Pennsylvania law, a sentence of death is mandatory if a jury unanimously finds at least one aggravating circumstance and no mitigating circumstances or unanimously finds that one or more aggravating circumstances outweigh the mitigating circumstances. The court noted that if one juror found that the aggravating circumstances did not outweigh any mitigating circumstances, then Mr. Saranchak would have been sentenced to life imprisonment. The circuit court found that the earlier PCRA court had misapplied the law by opining that Mr. Saranchak's mental health history would not have swayed even one juror under the case's facts and Mr. Saranchak therefore was not prejudiced. The circuit court pointed out that Mr. Saranchak was not required to establish prejudice by showing that one juror would have been swayed, but instead, that he only had to show a reasonable probability that the outcome would have been different absent counsel's errors. The court found that the presentation of Mr. Saranchak's mental health history to the jury could have been a vital mitigating factor that would have supported a sentence of life imprisonment. Accordingly, the Third Circuit Court overturned the death sentence.

Discussion

The Saranchak court weighed the importance of mental health evidence in the guilt and penalty phases of trial. Failure to present a defendant's history of mental problems alone during either trial phase will not automatically render a conviction or sentence defective, since courts will weigh the probable impact of such evidence against the factual circumstances of a particular case. A defendant exhibiting signs indicating mental health problems, as in this case, should have prompted a full psychiatric evaluation, especially in the setting of a capital case. Such an evaluation may not provide a viable defense or grounds to suppress a confession at the guilt phase, but it is difficult to argue that the evaluation would not be beneficial to a capital defendant during the penalty phase. Further, sole reliance on an evaluation limited to the question of competence to stand trial to determine the need for further evaluation is problematic, even if a defendant is not forthcoming about his personal history.

There may be numerous reasons why a defendant or his family would not disclose the defendant's mental health history or dysfunctional family dynamics, including stigma or shame. However, that lack of disclosure does not absolve counsel from the responsibility of investigating a defendant's mental health when other sources point to such a history. Mitigation offers the defense an opportunity to humanize a capital defendant, countering the prosecution's charge to present aggravating factors to secure a death sentence. Failure to attempt to humanize a capital defendant through mitigating evidence pointing to his personal circumstances, including problematic psychological and developmental histories, precludes a jury from weighing the entire picture as the law intended during the penalty phase.