A convicted killer and rapist has been granted a reprieve from the death penalty due to changes in the legal definition of intellectual disability.
A Tarrant County Court found Juan Segundo guilty of murder and rape in 2006 in connection with a crime committed in 1986. For his crime, Segundo was sentenced to death, a decision which also vacated the opportunity to try him for three additional murders linked to him through DNA evidence.
On May 25, the Texas Criminal Court of Appeals overturned the sentence and commuted it to life in prison, giving Segundo an opportunity for parole as soon as 2026, according to a press release from the Tarrant County Criminal District Attorney’s Office.
The Courts altered the convicted killer’s sentence after the definition of “intellectual disability” was changed, first in 2016, then again in 2018. The courts had previously rejected his attorneys’ claims that Segundo had an intellectual disability based on the standards that existed at the time. Before 2013, the American Psychiatric Association (APA) Diagnostic and Statistical Manual of Mental Disorders version IV termed Intellectual Disability as “mental retardation” and used an IQ test to determine the level of severity. Segundo tested at or above the limit for mild disability, making him eligible for the death penalty for his crime.
The Tarrant County CDA news release states that “forensic psychologist Dr. Stephen A. Thorne changed his mind about Segundo’s intellectual status because of the shift in diagnostic criteria in the newest manuals.”
The Texas Court of Criminal Appeals stated that the diagnostic criteria stated in the manuals were “revised so drastically and pervasively that what it even means to be intellectually disabled has substantively changed.” The court’s statement added, “That only means that the mental health experts’ understanding of the condition has evolved.”
Segundo was convicted of the rape and murder of 11-year-old Vanessa Villa in 1986, though he was not arrested until 2005, when DNA evidence linked him to the crime.
Police believe that Segundo entered the home Villa shared with her mother and two siblings, along with others who shared the partitioned home. Because there were numerous potential suspects, Segundo was investigated but did not become a focus of the investigation. According to the family, he even attended the memorial service held for Villa one week after her murder.
Between the 1986 rape and the murder in Fort Worth that lead to his 2005 arrest, Segundo was also linked to three other murders. The first was the kidnapping, rape, and murder of Melissa Badillo, 23, of Fort Worth, in September 1994.
Maria Reyna Navarro, 32, was allegedly kidnapped, raped, and murdered by Segundo on June 16, 1995, and found the next day discarded in Buck Sansom Park. Her death was also linked by DNA to Segundo in 2005 as he faced capital murder charges stemming from Villa’s death. Segundo is also a suspect in the 1995 murder of Francene Williams.
Anna Tinsley Williams, communications officer for Sharon Williams, Tarrant County Criminal District Attorney, spoke to The Dallas Express about the guidelines in place for sentencing at the time of Segundo’s conviction.
When Segundo was convicted for the murder of Villa and sentenced to death, the other cases against him were dismissed, Tinsley Williams said.
“The date of offense controls the punishment,” she explained in an email. “The offense occurred in 1986, and, at that time, anyone sentenced to life in prison had to serve 20 years before being eligible for parole. There was no life in prison without parole sentence at the time.”
The American Psychiatry Association says that today the term “intellectual disability” is associated with mental abilities in two areas: intellectual and adaptive functioning. The first refers to an individual’s ability to learn, solve problems, and make sound judgments. The second refers to an individual’s inability to function independently. Psychologists no longer use an IQ test to determine the level of disability, as was done when Segundo was initially convicted and sentenced.
According to the Texas Department of Health and Human Services, intellectual disability is determined using a three-pronged approach. Similar to the APA, Texas currently determines the intellectual competence of an individual by looking at the individual’s measured intelligence, personal independence, and age of onset.
Segundo was initially scheduled to be executed by lethal injection in October 2018, but his execution was delayed while the courts reviewed the change to the intellectual disability criteria, which his defense lawyers claimed made Segundo ineligible for the death penalty in Texas.