A Pennsylvania man who killed his wife and maimed her corpse cannot be executed, the state Supreme Court has ruled, because he is mentally disabled.
The justices had initially affirmed Connie Williams’ death sentence in 2004 after a jury found him guilty of killing his wife and cutting off her limbs and head, as the record was devoid of any evidence that Williams was mentally impaired.
But after a Post-Conviction Relief Act hearing in which Williams, now represented by a federal defender, put on five experts who concluded he was mentally retarded, an Allegheny County judge vacated the man’s death sentence and re-sentenced him to life in prison.
Rejecting arguments from the state that Williams was suitable for execution because he had been able to provide for his family and had shown signs of other adaptive skills, the Supreme Court unanimously followed suit.
The court cited at length the testimony from Williams’ experts, one of whom described the killer’s life as a "’series of failures.’"
Writing for the court, Justice J. Michael Eakin said the PCRA court could still find Williams mentally retarded despite the fact that he was the main provider for his family and that he was able to hold basic jobs.
"As expressed by several of appellee’s experts, the focus should be on an individual’s weaknesses — not his or her strengths — as mentally retarded people can function in society and are able to obtain and hold low-skilled jobs, as well as have a family," Eakin said.
Among his weaknesses, according to expert testimony, were low IQ scores and deficiencies in adaptive behavior. Williams couldn’t read, needed assistance at his jobs and was "consistently manipulated by others," Eakin noted. He also has a record of neglecting his health by refusing treatment for his diabetes, the opinion said.
Williams put on Dr. Daniel Martell, an assistant clinical psychiatrist, Dr. Barry Crown, the head of neuropsychology at Miami Children’s Hospital, Dr. Jethro W. Toomer, a forensic psychologist, Dr. William Musser, a neurologist and psychiatrist, and Dr. Julie Kessel, a board-certified psychiatrist.
All of the experts testified that Williams fell within the range of mental retardation in terms of intellectual and adaptive limitations. Testimony was also offered for the proposition that Williams had been mentally impaired since he was young.
Two experts for the state, on the other hand, agreed that Williams exhibited signs of "borderline intellectual functioning," which falls in between mental retardation and an average IQ. The state called Dr. Daniel Marston, a psychologist, and Dr. Bruce Wright, a psychiatrist who is the medical director at St. Clair Hospital in Pittsburgh.
Wright observed Williams did not have significant impairments in adaptive functioning such as communication (which Wright gleaned from police interviews), self-care, home living, self-direction and health safety. (Williams’ refusal for treatment for his diabetes stemmed from his fear of being used as an experiment, leading Wright to believe Williams may suffer from a psychotic condition rather than retardation).
The PCRA court determined that Williams had an IQ score between 70 and 75 — within the range for retardation — and was significantly limited in adaptive functioning. The court also considered below-average IQ scores from Williams’ childhood, which attorneys for the state contested were biased and affected by the severe child abuse Williams faced.
Through counsel, Williams argued the evidence points to the fact that he is mentally retarded under the standard in the state’s seminal case, Commonwealth v. Miller, which was the first Pennsylvania case to apply the U.S. Supreme Court’s decision in Atkins v. Virginia. In 2002, the U.S. Supreme Court ruled in Atkins that it is unconstitutional to execute mentally retarded people.
The widespread standard has developed to be a preponderance of the evidence as to whether an individual has below-average intellectual functioning, significant adaptive limitations and an early onset of impairment (before age 18).
A jury found Williams guilty of first-degree murder and abuse of corpse. According to the Supreme Court’s opinion the first time Commonwealth v. Williams went up on direct appeal, Williams admitted to police that he stabbed his wife, Frances, to death in 1999 and later admitted to taking a hacksaw to the body, cutting off his wife’s head, hands and feet.
Williams’ attorney, Billy Horatio Nolas of the Federal Community Defender Office did not return a call requesting comment.
Ronald Michael Wabby Jr. of the Allegheny County District Attorney’s Office represented the state and did not return a call requesting comment.
(Copies of the 25-page opinion in Commonwealth v. Williams, PICS No. 13-0168, are available from Pennsylvania Law Weekly. Please call the Pennsylvania Instant Case Service at 800-276-PICS to order or for information.) •