Michael Wayne Hall

Case record: Michael Wayne Hall

Background

Michael Wayne Hall was tried in Texas state court for the murder of Amy Robinson and convicted of capital murder by the jury. He was sentenced to death.

Hall pursued state and federal habeas relief, requesting a live evidentiary hearing on his claim of mental retardation. Each court denied his request, and he sought review in the United States Supreme Court and the United States Court of Appeals for the Fifth Circuit.

After Hall’s conviction and sentence of death were affirmed in state court, he sought state postconviction relief and then federal habeas relief. The United States District Court for the Northern District of Texas denied the petition, and Hall appealed.

In the United States Court of Appeals for the Fifth Circuit, the court held that Hall was entitled to an evidentiary hearing on the issue of whether he was mentally retarded, and therefore ineligible for the death penalty. The judgment of the federal district court was vacated and the matter was remanded for further proceedings including an evidentiary hearing.

Judge Patrick E. Higginbotham filed an opinion concurring in part and dissenting in part.

The offence

Hall and Robert Neville went to the Kroger grocery store in Arlington where their friend and former co-worker, Amy Robinson, worked as a checker. They waited in their car for Robinson to ride by on her bicycle.

Hall and Neville had a rifle, a pellet gun, ammunition, and a crossbow with them. When Robinson rode by, Hall and Neville coaxed her into their car, promising that they would drop her off at work after taking a short drive in the country.

After driving about twelve miles from the store, Neville pretended to have a flat tire and pulled the car over. Hall persuaded Robinson to exit the car. As Robinson walked toward Neville, he fired a crossbow at her several times, all of which missed. Hall shot Robinson in the back of the leg with his pellet gun. Hall and Neville laughed at Robinson when she cried in pain.

Neville then obtained a .22-caliber rifle from the car and shot Robinson in the chest. Hall then shot Robinson in the chest “three or four or six times” with the pellet gun. Neville killed Robinson with a shot to the head.

After the killing, Hall and Neville left Robinson and her bicycle where they would not be easily discovered, and then left. They returned to the scene a few days later. Neville fired shots into Robinson’s body, and Hall took keys and money from Robinson’s pocket.

Hall told authorities that he decided to kill someone because he was angry that he had a “sucky-ass” life. In television interviews after their arrests, Hall and Neville bragged about the killing. A tape of the news interview was played to the jury.

Investigation

Hall’s mother reported to the police that Hall had been missing for several days. Hall’s stepbrother told the police that Hall told him that Hall and Neville had abducted and killed Amy Robinson.

Hall and Neville were arrested while trying to cross the border into Mexico. Robinson’s body was discovered the same day.

Arrest

Hall and Robert Neville were arrested while trying to cross the border into Mexico.

Trial

At trial in Texas state court, the jury convicted Hall of capital murder.

In the sentencing phase, Hall offered evidence of his learning disability. Hall’s mother and brother testified about mental problems and learning disabilities in the family, Hall’s struggles to perform typical childhood tasks, childhood injuries to his head, and later difficulties when he started work and attempted to socialize with colleagues.

School psychologist and other experts discussed Hall’s mental capacity at school and discussed results from Hall’s IQ tests, ranging from 67 to 71 for full-scale IQ tests. They differed as to their significance, reliability, relevance, and margin of error.

Dr. Cunningham assessed Hall’s adaptive functioning and concluded that tests indicated that Hall was learning disabled, with “significant academic deficiency.”

Dr. Price assessed Hall’s adaptive knowledge using a Street Survival Skills Questionnaire. Dr. Price’s assessment indicated that Hall was “slow on a lot” of the questions, while his intelligence was “either borderline, right at the level of mild mental retardation, or he's mildly mentally retarded.” Dr. Price concluded: “it's sort of a judgment call.”

Sentencing

Hall was sentenced to death by the Texas jury.

In closing arguments, the state and the defense focused on Hall’s mental capacity as it related to mitigation. The state argued that Hall was “at worst mildly retarded” and that this was not mitigating, since Hall was “smart enough” to choose a trusting victim.

Hall’s attorney discussed Hall’s IQ in the broad sense and emphasized Hall’s inability to understand the wrongness or “grasp the horribleness” of the crime.

The state’s final rebuttal argued: “does it really matter to us, other than for labeling purposes, whether he's labeled as mild mentally retarded or low normal? Does that really tell us anything that we need to know or help us in determining is this a mitigating factor?”

The jury answered “no” to the question of whether there were mitigating circumstances to spare Hall’s life.

Appeals

Hall v. State, 67 S.W.3d 870 (Tex.Crim.App. 2002) (Direct Appeal)

Hall v. Texas, 537 U.S. 802, 123 S.Ct. 70 (2002) (Remand)

Hall v. State, 160 S.W.3d 24 (Tex.Crim.App. 2004) (Direct Appeal After Remand)

Hall v. Quarterman, 534 F.3d 365 (5th Cir. 2008) (Habeas)

Outcome

After the Fifth Circuit’s ruling, the matter was remanded to the federal district court for an evidentiary hearing, including a determination of whether Hall was mentally retarded.

Hall was executed by lethal injection in Texas on February 15, 2011.

Aftermath

The record listed a special meal for Hall: Chicken cooked three different ways, pizza, brownies, sweet iced tea, milk and vanilla pudding.

Hall’s last words were:

"I would like to give my sincere apology to Amy's family. We caused a lot of heartache, grief, pain, and suffering, and I am sorry. I know it won't bring her back." He continued speaking, saying he was changed by Christ and was not the same person anymore, and asked for forgiveness. "I am sorry for everything. I wish I could take it back, but I can't."