Barry M. Crown, Ph.D.
October 28, 1994
SCOTT, Paul William Data of contact Evaluation: 4 - 07 - 94
Paul William Scott, a 38 year old male, was examined on April 7, 1994. he is presently
under a death sentence following a 1978 incident and subsequent
trial and conviction.
In addition to a comprehensive neuropsychological examination
objectively investigating the relationships between Paul Scott's brain
function and behavior, the following documents were reviewed:
1979 trial testimony
Florida Supreme Court opinion on direct appeal
Procedural history of case
Florida Department of Corrections file on Paul Scott
Affidavits, statements and documents from relative, friends, acquaintances
Records of California Youth Authority
Records from other California authorities
Paul William Scott was born George Cook, Jr. on May 9, 1956 in San Diego,
California. Since birth, his life was one of constant abuse, chaos,
and confusion. After suffering years of physical, sexual and emotional
abuse by his father, he changed his name to Paul Scott
Paul was disabled from birth with Fetal Alcohol Syndrome. From neuro-developmental
complications, toxic exposure and head trauma, he has frontal lobe
brain damage. he has an IQ of 69 which places him in the retarded range.
Paul Scott's father, George Cook, Sr. had been married twice before he married
Paul's mother, and he was to marry three more times by the time Paul was twenty three.
The family was constantly on the move and in the first four years of Paul's
life, they lived in Texas, Massachusetts, Alabama, and Florida.
Paul's father was often away. When he was home, he viciously beat and sexually abused
Paul. Just before leaving again, he would give Paul one last
beating to "remind" Paul not to get into trouble while he was gone.
After the divorce, Paul's family lived in even greater poverty and chaos
When he was eight, he received a severe head injury when another
child struck him in the head whit a hatchet a constant stream of men
in the small apartments.
The family never had much money, but after the divorce, they sank into extreme poverty
living in various housing projects. Paul spent his adolescent life in the Carmalitos Housing Project in Long Beach,
California. Violence, crime, and poverty were a way of life in the project. There were
no outside friends or family in the community to provide support.
Two years after the divorce, Paul's father visited the family only to find them
in a terrible situation of filth, poverty, promised to take Paul
and his sister to live on a farm in Florida which he described to them at length. In order to
go to this wonderful place, he told Paul that his dog would have
to be killed. After much agony, Paul let his father dispose of his dog. The
next day when the children had their things packed, he appeared, said he had
changed his mind, and left. The broken promises. psychological cruelty, and physical and sexual
torture had taken their toll and this was the final straw. Paul
experienced severe emotional impairment and despite attempts at interventions,
never completely recovered.
Paul Scott's relationship with his mother was very destructive. Delores
Carl suffered from mental illness and was unable to provide ordinary nurturance, guidance,
and support, much less the special care that her emotionally and
mentally disabled child required. Instead, Paul became the scapegoat
of the family and received the blame for everything that went wrong.
The only attention Paul received from his mother came in the form of
When he was ten, Paul developed a relationship with a neighborhood
girl from a well-to-do family. For a short time, he received love and attention
from that family - concern that had never been expressed by his own family. Then
Paul's mother decided to move 600 miles away, and arbitrarily refused
to allow further contact with the other family. Once again, Paul's world was shattered.
Out of desperation, he took a car to try to get back to the family
and the only love he had ever known.
The children with whom Paul attended school never accepted him. In fact, they
openly ostracized him at every turn. Although he desperately sought
acceptance, he never got it. Easily led and directed, he would do anything for
anyone who might show him some attention. These attempts only led to
While still in his pre-adolescent years, Paul turned to both alcohol and drugs
as a way to alleviate emotional pain and to "treat"
his mental/ organic problems. The schools did not have the resources to help him and,
on one occasion, a teacher punched him the eye. Finally, his behavioral and emotional
problems became so extreme that the school referred him out when he
was 11 years old. Instead of conducting a comprehensive
psychological and and neuropsychological evaluation to assess attentional problems
and brain damage or providing counseling and special classes,
Paul receive anti-psychotic medications such as Mellaril and Thorazine.
He was not able to progress beyond the seventh grade.
These medications not only failed to address Paul's emotional and physical
problems, but they turned him toward and reinforced his use of illicit drugs
as a way to cope with his problems. At the age of 11, paul began to experiment. He
began sniffing glue, and by age 14, he was using speed (amphetamines), downers
8barbiturates and hypnotics), and LSD. By age 15, he was using heroin,
and by age 16, he was severely addicted. Although on several occasions
he was committed to the supervision of the California Youth Authority,
he was never provided with drug treatment.
At the age of 15, Paul sustained another severe head injury. He was involved in a very serious
motorcycle accident which resulted in head injuries and required hospitalization.
Paul Scott was known by his friends to ben kind-hearted, but also weak, and easily led. At 16, he came under the influence
of an older man named Melvin Touchstone who was living with his sister. Touchstone formulated
the idea of robbing a neighborhood liquor store and intimidated Paul into
going with him. Paul told him he couldn't go through with it and was threatened
with violent behavior by Touchstone. Touchstone shot the clerk in the course of the robbery.
The next day, when Paul Scott heard that the clerk had died, he went to the police on his own and told them everything.
In this search for love and attention, Paul had started living with a woman who was 10 years
older. She has recalled bringing heroin to Paul while he was in a youth camp.
At this time, the prosecutor, because of Paul's lack of involvement,
offered to have him sentenced as a juvenile if he would plead competency assessment or
brain damage assessment. Scared and mentally disabled,
Paul Scott relied on his court-appointed lawyer to make decisions for him. When his
attorney hold him to plead guilty, he did.
Paul remained in custody for two years. He worked at learning a trade.
He was paroled back to the projects without drug treatment or after care
and relapsed as a result of the pressures of the environment. His mother
put him on the street and the Youth Authority listed him as an absconder in October 1978.
Paul left California with a girlfriend hoping for a geographic cure.
The couple stayed with Paul's father in North Florida and headed to the
Fort Lauderdale. It was at this time that Paul became "Paul Scott" having rejected
his father. While in Fort Lauderdale, Paul came under the influence of Richard
Kondian and the incident for which he was convicted ensued.
Paul Scott's intellectual capacity was objectively tested utilizing the Wechsler Adult Intelligence
Scale-Revised which yielded scatter and a Full Scale IQ (DIQ) of 69.
This is within the retarded rage. (The American Association or Mental Deficiency places
retardation at 74 and lower.)
Abstract reasoning and problem-solving capacities as measured objectively
by the Shipley Institute of living Scale is 9 years, 4 months.
Memory process assessment places Paul Scott between mental ages of 5-4 and 6-8-
He has a significant auditory selective attention disorder with a percentile rating of
1. (99 of 100 individuals would do better on this tests of auditory attention.)
Listening comprehension is at mental age 4-10.
Attention and vigilance measurement places him at mental age 6-10.
Oral vocabulary assessment (with a reasoning component) is measured at mental age 10-8; Verbal Analogies
is at mental age 5-11, and Picture Vocabulary is at MA 11-9. (Picture Vocabulary involves rote behavior while
other language assessment require reasoning.)
Visual Closure produced a mental age of 6-11.
Concept Formation produced at mental age of 6-0. There were no correct
responses on a test measuring analysis and synthesis.
Affective decoding (ability to detect emotion from facial expression) is
He is easily led and directed.
He is unable to assess the long-term consequences of his immediate behavior.
Testing of specific frontal lobe functioning was in the significantly
impaired (organic brain damage) range.
The findings of this examination indicate that Paul Scott is retarded
by IQ and adaptive capacity measures. He has a diffuse, bilateral anterior neuropsychological
There is an Organic Brain Syndrome, Mixed and Frontal Lobe Syndrome.
There is likely to be a multiple causative basis - neuro-developmental complications,
toxic exposure, and head trauma.
Based upon an examination of documents and a comprehensive neuropsychological
evaluation, the following conclusion are reached pertaining to both
aggravation and mitigation circumstances:
The defendant was previously convicted of another capital felony or of a felony
involving the use of threat of violence to the person.
Paul Scott was led and directed into his prior involvement. He did not have the
reasoning capacity to participate, nor did he have the capacity to effectively
consult with his attorney and understand the ramifications of his plea.
The capital felony was committed while the defendant was engaged, or was an accomplice
, in the commission of, or an attempt to commit, or flight after committing or attempting to commit...
Paul Scott's organic brain damage impairs his ability to determine the long term
consequences of his act. He is easily led and directed.
The capital felony was committed for pecuniary gain.
Paul Scott has the reasoning and concept formation capacity of a child.
He is easily led and directed.
The capital felony was especially heinous, atrocious or cruel.
Paul Scott's frontal lobe bran damage renders him in,capable of assessing the long-term
consequences of his immediate behavior. He is easily led and directed
The capital felony was committed while the defendant was under the influence
of extreme mental or emotional disturbance.
Paul Scott has organic brain damage. This is a permanent condition which results
in extreme mental and emotional disturbance. It is exacerbated by drug
and/or alcohol use.
The defendant was an accomplice in the capital felony committed by another person and his participation
was relatively minor.
Paul Scott was led into this situation by another. Paul Scott is easily led
and directed. His participation was relatively minor in contrast to the other
The defendant acted under extreme duress or under substantial domination of another
Paul Scott is retarded. He has limited reasoning capacity. he is easily led
and directed. He was led and directed by others.
The capacity of the defendant to appreciate the criminality of his conduct
or to conform his conduct to the requirements of law was substantially impaired.
Paul scott has organic brain damage. This is a permanent condition. As a
result of this condition, he is unable to comprehend the long-term consequences
of his immediate behavior. Under stress, duress, and/or substances, he is
unable to appreciate the criminality of his conduct or to conform his conduct to
the requirements of law.
NON-STATUTORY MITIGATION CONSIDERATIONS
A) Paul Scott is retarded with an IQ of 69.
B) Paul Scott's reasoning and problem-solving capacities are below that of
a 10 year old child.
C) Paul Scott is learning disabled.
D) His organic defects were undetected and mis-identified during his childhood
resulting in improper treatment including treatments with large doses of anti-psychotic
E) That because of his emotional and intellectual deficits as well as
his organic brain damage, he has poor impulse control.
F) That because of his emotional and intellectual deficits, as well as his
organic brain damage, he has difficulty in foreseeing the consequences of his actions.
G) That at the time of the offense, due to the use of drugs and
alcohol, coupled with his organic brain damage and low intelligence, the capacity of
Paul Scott to appreciate the criminality of this conduct and to conform
his conduct to the requirements of the law was impaired.
H) That at the time of the offense, due to the use of drugs and alcohol,
coupled with his organic brain damage, the offenses
were committed whole Paul Scott was under the influence of mental and/or emotional
I) That during her pregnancy the mother of Paul Scott used and abused substances
resulting in his birth with Fetal Alcohol Syndrome.
J) As a child, Paul Scott was subjected to physical, emotional, and sexual
K) Paul Scott had an impoverished upbringing.
L) Paul Scott was raised in a grossly dysfunctional family, with no stable
M) Paul Scott has not been a disciplinary problem and can adequately
adjust to life imprisonment.
All of these findings, conclusions, and opinions are based upon a reasonable
degree of psychological probability.
Barry M. Crown, Ph. D.
Diplomate, American Board of
Certified Addictions Specialist