California Supreme Court Grants New Trial in 30-Year-Old Death Penalty Case

The California Supreme Court grant­ed Nvwtohiyada Idehesdi Sequoyah (tried as and referred to in court doc­u­ments as Billy Ray Waldon) a new tri­al on January 23, 2023 after over­turn­ing his 1992 death sen­tence and con­vic­tion. Sequoyah was per­mit­ted to rep­re­sent him­self at tri­al despite strong evi­dence that he was incom­pe­tent to do so. The new rul­ing deter­mined that the tri­al court had failed to pro­tect a men­tal­ly ill man.

Prior to his tri­al, Sequoyah was exam­ined by a psy­chi­a­trist, who con­clud­ed that he could not appre­ci­ate the ram­i­fi­ca­tions of waiv­ing coun­sel, and like­ly suf­fered from a delu­sion­al thought dis­or­der and para­noia. The recent rul­ing focused on the tri­al court’s deci­sion to allow Sequoyah to pro­ceed without counsel. 

The California Supreme Court deter­mined that the low­er court act­ed arbi­trar­i­ly and irra­tional­ly by not address­ing any of the pre­vi­ous evi­dence of incom­pe­tence. This judi­cial fail­ure vio­lat­ed Sequoyah’s right to coun­sel because he could not valid­ly waive the right, and, sub­se­quent­ly, it vio­lat­ed his right to a fair tri­al because a tri­al where a defen­dant is denied coun­sel with­out valid­ly waiv­ing the right is fundamentally unfair.

In 2020, the Inter-American Commission on Human Rights held that the United States was respon­si­ble for vio­lat­ing Sequoyah’s ​“right to humane treat­ment” because his extend­ed incar­cer­a­tion under the threat of death was ​“cru­el, infa­mous, or unusu­al pun­ish­ment.” The IACHR fur­ther held that the rem­e­dy for Sequoyah would be to com­mute his death sen­tence to life in prison.

While Sequoyah’s con­vic­tion and death sen­tence were over­turned, the pros­e­cu­tion can still retry him for a cap­i­tal offense, with the pos­si­bil­i­ty of his return to death row.