Background
Seth T. Strickland was charged with second-degree murder for fatally shooting his mother, Joyce Strickland, in their DeSoto Parish home in August 2023. Afterward, he called 911, was arrested without resistance, and made statements to relatives concerning “other realities,” supernatural beings, and police officers turning into snakes.
A sanity commission initially found Strickland incompetent to proceed, and he was committed to Eastern Louisiana Mental Health System for restoration treatment. The district court found him competent in April 2025. At the start of his October 2025 trial, with the State’s agreement, the court allowed him to change his original not-guilty plea to a dual plea of not guilty and not guilty by reason of insanity. A jury unanimously convicted him of second-degree murder.
The Court’s Holding
The Second Circuit affirmed the conviction. It held that the trial court adequately protected Strickland’s right not to be tried while incompetent: he had received a competency evaluation and restoration treatment, was adjudicated competent six months before trial, and neither party raised a renewed competency concern or presented evidence requiring the court to revisit the issue. The appellate court also found no reversible error in accepting the late dual plea. The record showed that Strickland was present with counsel, both sides believed the plea had already been entered, and the circumstances established good cause.
The court nevertheless vacated Strickland’s mandatory life sentence. Although he had filed motions for post-verdict judgment of acquittal and for a new trial six days before sentencing, the district court did not rule on either motion before imposing sentence. That violated Louisiana procedural rules requiring disposition of those motions before sentencing. The case was remanded for rulings on the pending motions and, if appropriate, resentencing after the required delay.
Key Takeaways
- A prior competency adjudication need not be revisited absent a bona fide renewed doubt about the defendant’s capacity to proceed.
- A late insanity plea may be accepted upon a sufficient showing of good cause and no dilatory purpose.
- A sentence imposed before the trial court rules on pending post-verdict acquittal and new-trial motions must be vacated.
Why It Matters
The decision distinguishes between errors affecting the validity of a conviction and mandatory sentencing-sequence requirements. Even where the conviction and competency proceedings withstand review, a trial court must resolve timely post-trial motions before sentencing.