The Supreme Court of California Monday reversed Billy Ray Waldon’s conviction and death sentence from 1991. The court agreed with Waldon that the trial court judge wrongly allowed Waldon to represent himself at trial, even after a prior judge denied his request. The court stated that the trial court’s failure to provide counsel for Waldon violated his constitutional rights to counsel and a fair trial.
Waldon requested to represent himself during the criminal trial, so the judge ordered a psychiatric exam of Waldon. The psychiatrist that examined Waldon reported that Waldon did not have the capacity to understand the consequences of waiving counsel and also believed he had a delusional thought disorder. The judge denied Waldon’s motion to represent himself, citing the psychiatrist’s report. A second judge, without considering the psychiatric report, then permitted Waldon’s second request to represent himself at trial.
A jury convicted Waldon of three counts of first degree murder, attempted murder, arson, sexual assault, burglary, theft of a vehicle, robbery, multiple firearm counts and animal cruelty. The court sentenced Waldon to death.
This case represents an instance of the decline in the use of the death penalty in the US. At the end of last year, the Death Penalty Information Center reported that since 1973, almost 200 people on death row have been found innocent.