The Planning of a Murder Show That a Defendant Did Not Suffer from Mental Retardation
In Phillips v. State, 984 So. 2d 503, 509 (Fla. 2008), the Supreme Court of Florida held that there was competent, substantial evidence to support the trial court's determination that Phillips did not suffer from deficiencies in adaptive functioning.
In that case, the evidence established that Phillips was able to support himself and his daily behavior:
Phillips supported himself.
He worked as short-order cook, a garbage collector, and a dishwasher.
The mental health experts generally agreed that Phillips possessed job skills that people with mental retardation lacked.
Specifically, the defense's expert admitted that Phillips's position as a short-order cook was an "unusually high level" job for someone who has mental retardation.
Phillips also functioned well at home.
He resided with his mother.
According to her, he paid most of the bills and did the majority of the household chores.
Phillips was also described as a great son, brother, and uncle.
Phillips purchased a new car for his mother and a typewriter for his sister.
He spent a lot of time with his nieces and nephews, and "was real good with them."
Phillips often kept the children overnight, took them for ice cream, and would give them rides when needed.
In addition to driving, Phillips cooked and went grocery shopping, skills that are indicative of the ability to cope with life's common demands. Phillips v. State, 984 So. 2d at 511.
Moreover, "the planning of the murder and cover-up" and Phillips' actions during the murder itself were "inconsistent with a finding that Phillips suffers from mental retardation."
The Court explained:
To commit the crime, Phillips, having discovered that his parole officer was generally the last to leave the office, lay in wait behind dumpsters outside of the building.
When the parole officer emerged and there were no witnesses present, Phillips unloaded his gun into the officer.
He reloaded the gun and shot the parole officer three more times.
Phillips then retrieved the shell casings from the ground, fled the scene, and disposed of the gun.
After he was apprehended, officers tried on several occasions to interview Phillips, but he refused to speak. Id. at 512.
The court ultimately concluded that "Phillips's ability to orchestrate and carry out his crimes, his foresight, and his acts of self-preservation indicate that he has the ability to adapt to his surroundings." Id.
The Court then stated:
"It is clear from the evidence that Phillips does not suffer from adaptive impairments.
Aside from personal independence, Phillips has demonstrated that he is healthy, wellnourished and wellgroomed, and exhibits good hygiene." Id.