A South Carolina judge has ruled that a death-row inmate's long-held beliefs — including that most laws are unconstitutional and that citizens have an absolute right to defend property to death — do not establish legal incompetency and allowed his execution to move forward, at least for now.
Judge R. Scott Sprouse wrote that Steven Bixby, 58, cooperates with his lawyers and the psychiatrists who evaluate him, and that his disagreements with counsel do not show he lacks the capacity to participate in his defense. Bixby was scheduled to be executed in May for the 2003 killings of two law enforcement officers before the state Supreme Court paused the execution to review questions about his mental competency. Bixby's attorneys may seek to appeal the lower-court ruling.
At a competency hearing last month, defense lawyers told the court that Bixby is convinced the U.S. legal system is unconstitutional and refuses to provide information that could help him avoid execution. Defense experts said prolonged isolation on death row has entrenched Bixby's beliefs and made them more delusional. Prosecutors countered that Bixby's views are shared by others and that he understands why the state seeks to carry out his sentence.
Sprouse cited testimony from two state experts who have evaluated Bixby since shortly after the 2003 slayings, saying those evaluators acknowledge Bixby will not abandon his beliefs but that he nevertheless understands the purpose of the competency proceedings and the roles of his attorneys. The judge noted that "while Bixby has often disagreed with counsel and expresses distrust regarding their strategy in this proceeding, the evidence demonstrates that he understands their role, the rationale for why they are engaging in this competency proceeding, and that he can choose whether or not to cooperate with them."
Bixby has filed handwritten motions in the case that include incendiary assertions. In one recent filing, he wrote that judges who rule against him are guided by Satan and suggested a presiding judge would commit treason if he failed to stop the execution and free Bixby from custody. He also wrote, "I am an innocent man!! Let freedom ring & let those committing treason swing!!! Like Thomas Jefferson: I am standing on principle even if I stand alone," according to court filings.
A psychologist who examined Bixby told the court that the inmate understands what led to his death sentence but holds unusual beliefs about physical evidence, at one point saying he believed blood found on his clothes the night of the killings contained the DNA of Jesus Christ. The psychiatrist who evaluates death-row inmates in South Carolina reported Bixby described his own mental state with the words, "I'm not crazy. I'm not a mental health case. I may be an [expletive], but I'm not crazy."
The killings occurred in December 2003, according to court records and law-enforcement accounts. Abbeville County deputy Danny Wilson was shot when he knocked on the front door of the Bixby family home after a dispute involving the family and a road crew. Wilson's dying body was pulled inside the home and restrained with his own handcuffs. State Constable Donnie Ouzts was later killed as officers responded to the home and an extended standoff ensued, during which investigators say the family and responding officers exchanged hundreds of rounds. Bixby's parents were charged in connection with the deaths but have since died.
Bixby was out of regular appeals when the state Supreme Court temporarily halted the execution in March to examine competency questions. The lower-court ruling clears the way for the state to proceed pending any appeal by Bixby's lawyers. Prosecutors have argued that Bixby's consistent statements about the law and his conduct do not amount to incompetence and that the state has the authority to carry out the sentence imposed after his conviction.
State experts at the competency hearing told the court that Bixby views himself in some respects as a martyr prepared to die for his beliefs if his appeals fail, and that he believes he will be reunited with his parents in heaven. Defense experts emphasized that those same fixed beliefs and the isolating conditions of death row have made Bixby's worldview more rigid and less amenable to traditional legal counsel.
The case will continue to move through post-conviction proceedings as Bixby's attorneys consider their options, including appealing Sprouse's competency ruling to state appellate courts. The state will also have the opportunity to seek to set an execution date if appellate avenues are exhausted and courts rule that Bixby is competent to be executed.
