McWilliams v. Dunn
Facts
McWilliams, an indigent capital defendant, received a state neuropsychological examination by Dr. Goff shortly before his judicial sentencing hearing, and defense counsel also received additional mental health records only at the last minute. Counsel repeatedly told the trial court that, as laymen, the defense could not interpret the new mental health materials and needed more time and expert help to review them and determine how to use them. The trial court denied continuances, did not provide expert assistance for evaluating, preparing, or presenting the mental health evidence, and sentenced McWilliams to death. The Alabama Court of Criminal Appeals held that Ake was satisfied because the State had allowed Dr. Goff to examine McWilliams.
Issue
Whether the Alabama Court of Criminal Appeals unreasonably applied clearly established federal law by concluding that McWilliams received all the assistance required by Ake when the State provided only a mental health examination, but no meaningful expert assistance in evaluating, preparing, and presenting the defense at sentencing.
Rule
When Ake's threshold criteria are met, the State must provide an indigent defendant access to a competent mental health expert who is sufficiently available to the defense and independent from the prosecution to conduct an appropriate examination and to assist in evaluation, preparation, and presentation of the defense. An examination alone does not satisfy Ake's minimum requirements.
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Assuming the threshold conditions for due process protection are met, which is the strongest argument that Vargas was denied the minimum assistance required?