Wilcoxson v. State
Bobby R. Wilcoxson, convicted of first-degree murder in 1986, appealed the denial of his post-conviction relief from conviction after his death sentence was reversed due to ineffective assistance of counsel. The core of his appeal alleged ineffective assistance of counsel during the guilt/innocence phase, primarily for failing to investigate his mental competency and the feasibility of an insanity or diminished capacity defense. Evidence presented included his extensive history of mental illness diagnoses (schizophrenia, bipolar disorder) and disruptive prison behavior, but his trial attorneys argued he was competent and actively involved in his defense. The appellate court affirmed the post-conviction court's judgment, finding counsel deficient for not requesting a psychological examination given the evidence, but ultimately concluded Wilcoxson failed to prove he was actually incompetent or prejudiced by counsel's decisions.