The U.S. Ninth Circuit Court of Appeals has overturned federal death sentences imposed on a child killer whose victims included a 10-year-old Beaumont boy, questioning the defendant's mental competence.
Joseph Edward Duncan, III, 48, was convicted in August 2008 of murdering an Idaho family, two of whose members – both children – he abducted and used as sex slaves for weeks before one was rescued.
Eleven years earlier, Duncan abducted, raped and killed Anthony Martinez from his Beaumont neighborhood after luring the youngster to his car with the promise of money for helping him find his lost cat.
Anthony's remains were located on Bureau of Land Management land east of Indio.
Like the Idaho crimes, Duncan admitted killing Anthony, and as part of a plea agreement reached earlier this year with the Riverside County District Attorney's Office. Duncan was sentenced to life in prison without the possibility of parole for the child's death.
District Attorney Paul Zellerbach, a former judge, explained during a March news conference that he didn't feel pursuing the death penalty in California would be worth it because Duncan had already received three death sentences stemming from the murders of the Idaho family.
In that case, Duncan broke into the Coeur d'Alene residence of Brenda Groene and her fiancee, Mark McKenzie, in the middle of the night on May 16, 2005. He bound the man and woman at gunpoint, then fatally beat them with a hammer.
He killed Brenda's 13-year-old son Slade in the same manner, then carried off 8-year-old Shasta Groene and her brother, Dylan. The defendant later confessed to spending days planning the crimes.
For several weeks, Duncan imprisoned the children at a remote campsite, sexually abusing and torturing them – acts he videotaped. Dylan was taken aside at some point and shot in the head, according to federal investigators.
Duncan kept Shasta with him. The missing girl and her brother's pictures were broadcast on television, and after she was spotted in a Denny's restaurant with Duncan, police were summoned and arrested him.
At his federal trial in Boise, Idaho, Duncan confessed to all the murders and special circumstance allegations. Before his penalty trial got under way, the previously convicted child rapist insisted on representing himself. His attorneys objected that he wasn't mentally competent and asked for a competency hearing.
Three psychologists retained by the defense raised doubts about Duncan's ability to comprehend the legal process. However, two state-appointed psychologists found that the defendant was not delusional and “could understand the nature and consequences of the proceedings against him,” according to the Ninth Circuit's findings.
The trial judge allowed Duncan to represent himself, and he offered no defense, resulting in unanimous jury recommendations that he be executed for the Idaho killings.
He had already pleaded guilty in Idaho state court and was sentenced to multiple life prison terms. Prosecutors in Kootenai County, Idaho, have reserved the right to conduct a penalty trial, leaving open the possibility that Duncan could yet face capital punishment at the state level.
According to the Ninth Circuit's ruling, there was sufficient basis for the judge who presided in the federal case to order a competency trial for Duncan before the penalty phase of his murder trial began.
The panel quoted the defense's experts, who referred to Duncan's bizarre ramblings about religion and his way of life as evidence of “delusional beliefs, paranoia, grandiosity and psychotic breaks from reality.”
The appellate court also pointed out that a magnetic resonance imaging study showed the defendant had an ``unusual brain structure consistent with behavioral deficits in the ability to make rational plans and modulate emotions.''
The Ninth Circuit remanded the case back to the trial court for a review of whether Duncan is competent. If there's a finding that he isn't, the previous death sentences must be vacated and a new penalty trial held.
CNS contributed to this story.
