From the Petition, pages 26-29
When Richard was in jail, his brain malformation caused him to become severely depressed and suicidal, causing him to falsely confess and behave antagonistically toward others to accomplish his suicidal desires. After Richard’s arrest, he suffered from drug withdrawal and severe depression. Richard had used cocaine intravenously all day at the time of the Mr. Honeycutt’s death, and he consistently used methamphetamines until two days before his arrest. Richard’s withdrawal after this prolonged drug use made him feel vulnerable, extremely depressed, and with no desire to live.
In essence, Richard committed suicide by confession when Officer David S. Null confronted him in a Florida jail on February 9, 2001. At trial, Richard testified that he voluntarily confessed to capital murder because he wanted the death penalty rather than a life in prison. Unfortunately, the jury did not believe him because his trial attorneys did not spend the time to consult with experts about Mr. Honeycutt’s cause of death, or Richard’s trauma, PTSD, and mental illnesses.
But besides that readily available scientific evidence, Richard had other serious brainchemistry problems that science had not recognized yet. Dr. Williams-Anderson examined Richard’s brain function in 2013 and found that he exhibited multiple neuropsychological deficits in his reasoning ability and had a brain anomaly. Exh. 8. Dr. Williams-Anderson believed that Richard’s substance abuse triggered frequent seizures. Id. When the brain is repeatedly exposed to drugs, it naturally adjusts its chemistry to tolerate the effects of the drugs and achieve stimulation. Exh. 9. Because stimulant drugs release dopamine and stimulate the brain to anticipate pleasurable events, Richard became profoundly energized and euphoric. So when Richard discontinued the stimulant drug use, his brain developed symptoms of hyperactivity and craved more drugs to maintain normality. Id. Dr. Wilke A. Wilson also conducted a research study on the effects of drugs on the adolescent brain, but general awareness of the research was not available until after the trial. Following a 2002 publication on psychostimulant drug use, the scientific community acknowledged a correlation between acute stimulant withdrawal and the symptoms of major depressive disorder. See AM Barr, A Markou, AG Phillips. A Crash Course on Psychostimulant Withdrawal as a Model of Depression. TRENDS in Pharmacological Sciences Vol. 23 No. 10 (1041-1052) October 2002. Severe depression combined with withdrawal from stimulants produces suicidal ideation. Exh. 9. At the time of Richard’s interrogation, he was suffering a major-depression episode because of stimulant withdrawal, known as “transient stimulant withdrawal depression.”
His confession was a desperate attempt to commit suicide. When the depression subsided, Richard no longer wanted the State to put him to death. He testified on his own behalf in a doomed attempt to convince the jury that he was not guilty of capital murder. Without this evidence to explain why Richard would make a false confession to capital murder, the jury rejected Richard’s pleas of innocence. After the jury convicted Richard of capital murder, he sank into his depressed, suicidal shell again. To further his suicidal goal, Richard once again took the stand during the sentencing phase and pled for a death sentence..
[ Omitted text ]
.. After Richard’s final letter asking the court to expedite his death, prison officials prescribed him Zoloft, a common anti-depressant. This common remedy alleviated the severity of Richard’s crushing depression and he filed a motion in the district court withdrawing his three previous letters volunteering for execution. He realized that he had been so deeply depressed that he had been attempting to commit suicide. After receiving a simple anti-depression treatment, Richard wanted to fight for his life.