Eleventh Circuit Court of Appeals - Published Opinions

Monday, August 15, 2005

Battle: Competent for trial

In Battle v. U.S., No. 03-14908 (Aug. 10, 2005), the Court (Edmondson, Birch & Black) (withdrawing its earlier opinion) denied § 2255 relief to a defendant sentenced to death for the killing a federal correctional officer.
The Court rejected Battle’s argument that he was incompetent to stand trial. "That Battle at times exhibited an antagonistic relationship with his lawyers over their representation of him is no indicator of incompetency. Many criminal defendants differ with their lawyers on how to best represent them." The Court further found that the district court did not error in siding with one set of experts instead of another in view of their "diametrically opposite" views. In addition, the court observed Battle throughout the trial.
The Court also rejected the argument that an insanity defense was forced upon Battle by his lawyers, finding that he at least tacitly consent to it.
The Court also rejected the argument that the indictment should have charged aggravating factors in order to be valid under Ring v. Arizona. The Court noted that Ring does not apply retroactively to cases like Battle’s.
The Court rejected Battle’s argument that the district court violated 18 U.S.C. § 3593(b), which requires the same jury which decided guilt to decide life or death, when it allowed alternate jurors to sit on the penalty jury after two jurors from the guilt phase had been dismissed for cause. The retention of alternates was a "wise" decision, and Battle suffered no prejudice because even if the alternates had less persuasive effect (for not having sat in on deliberations relating to guilt) a single vote against death would have sufficed to thwart a death sentence – and no alternate voted for life.