Georgia puts death row convict Willie Pye to death for killing Alicia Lynn Yarbrough in 1993.

TFD – Explore the court’s decision to dismiss Willie Pye’s claim of intellectual disability and its legal implications.

On Wednesday, Georgia executed Willie Pye, a death row inmate who was found guilty and given a death sentence for the 1993 murder of Alicia Lynn Yarbrough.

The execution, which was Georgia’s first in almost four years, took place in a prison in Jackson, around 50 miles south of Atlanta, at 11:03 p.m. via lethal injection, according to a news release from the Georgia Department of Corrections. Per the release, Pye refrained from making a conclusive statement.

Pye, 59, was executed late on Wednesday after his last round of appeals was turned down by the US Supreme Court. Pye and his attorneys have advocated for Pye’s life to be spared in a mercy petition and other court files, claiming an intellectual handicap, a difficult background, and inadequate legal help.

Georgia hasn’t seen an execution since January 2020, according to the nonprofit Death Penalty Information Center, which marks Pye’s execution. The American Bar Association has stated that the Covid-19 outbreak caused the executions to be halted there.

According to court documents, Pye was found guilty in 1996 of rape, burglary, armed robbery, kidnapping with bodily injury, and malice murder in the death of Yarbrough, with whom he had an intermittent love involvement.

A flurry of last-minute appeals, which are usual in capital cases, preceded the execution. Two of these appeals were filed with the US Supreme Court but were ultimately denied.

In one, Pye said that he shouldn’t be put to death because of a deal struck during the epidemic between the Georgia Attorney General’s Office and attorneys for the defense that essentially put a hold on executions in the state until a number of requirements were satisfied.

Pye’s lawyers claimed that the state had violated the equal protection and due process sections of the 14th Amendment by keeping Pye out of the deal and placing him in a “disfavored class of death row prisoners.” Citing a state court’s ruling that Pye was not a party to the agreement, the state urged the justices to reject Pye’s appeal.

Pye’s attorneys contended that his execution should be invalidated due to his intellectual handicap, which was the basis for the other appeal. However, Pye’s counsel claimed that Georgia’s standard of proof—that prisoners must demonstrate an intellectual handicap beyond a reasonable doubt—was so onerous as to be unconstitutional.

The state persuaded the Court to reject once more, partly because a state court had already dismissed comparable claims.

As is customary in emergency appeals, the Supreme Court did not provide a justification for its decision to deny Pye’s execution. Notable dissents were absent.

Alicia Lynn Yarbrough’s murder

According to an appeals court ruling, Pye planned to rob a guy Yarbrough was staying with along with two accomplices. Because Yarbrough had signed the birth certificate of a child Pye had claimed as his own, Pye was enraged with the man. Pye bought a .22 pistol before the three men went wearing ski masks to the man’s home, where Yarbrough was alone with the baby.

As stated in the court ruling, Pye kicked in the door and threatened Yarbrough with a revolver. Yarbrough was given a ring and necklace by the men, who then kidnapped her and brought her to a motel to sexually assault her.

After that, they drove Yarbrough down a dusty road, where, according to the court decision, Pye shot her three times, commanded her to lie face down, and ordered her out of the car. Later on, one of Pye’s accomplices came clean and gave a state-sponsored testimony. Pye’s DNA was also found in semen retrieved from the victim.

According to the Georgia Attorney General’s Office, Pye’s jury recommended a death sentence, which the court finally imposed in addition to three life sentences plus 20 years.

According to Georgia penitentiary records, Pye’s accomplices are also serving life sentences for their participation in Yarbrough’s murder.

Prisoner said trial lawyer “abandoned his post.”

Pye’s clemency petition argued that his sentence should be commuted to life in prison, citing his trial attorney’s incompetent assistance as a contributing factor. Pye passed away in 2000.

Indeed, three of Willie Pye’s jurors were opposed to his execution, citing factors in the inmate’s background that were not presented by what his clemency petition said was an overworked and ineffective public defender. The state parole board, however, was unconvinced: After meeting Tuesday and “thoroughly considering all of the facts and circumstances of the case,” it denied clemency, according to a news release.

At the time, that attorney “was responsible for all indigent defense services” for Spalding County, Georgia, through a contract for which he was paid a lump sum, the petition says.

In addition to Pye’s private practice, the petition claimed that Pye’s lawyer handled hundreds of felonies at the same time with the assistance of just one other lawyer and an investigator. The attorney was defending defendants in four other capital trials at the same time that he represented Pye. The lawyer so “effectively abandoned his post.”

His petition stated that jurors “would have learned that Mr. Pye is mentally challenged and has an IQ of 68,” significantly below the 100 average, if he had given Pye proper representation. The petition stated, “They would have also learned that the obstacles he faced from birth—extreme poverty, neglect, ongoing violence, and chaos in his family home—forclosed the possibility of healthy development.”

The US Supreme Court found in 2002 that an execution of this kind would violate the Eighth Amendment’s prohibitions against cruel and unusual punishment, reiterating the 1989 Georgia Supreme Court ruling that executions of intellectually disabled people violate the state constitution.

Nevertheless, according to Pye’s petition, Georgia is the only state that places the burden of proof at the “insurmountably high standard” of beyond a reasonable doubt.

Though in 2021 a three-judge panel of the 11th Circuit Court of Appeals annulled the sentence, finding that his trial attorney’s performance during the sentencing phase of Pye’s trial was poor and prejudiced, his conviction and sentence were sustained on appeal in state and federal courts. But a year later, after a hearing before the whole 11th Circuit, that decision was reversed.

Similarly, a state court previously reviewed Pye’s claim of intellectual disability but found in a 2012 ruling that Pye did not prove it required. Pye filed a similar appeal on Wednesday, but the court dismissed it, stating that the claim was successive, meaning that it had already been settled, citing the 2012 order.

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