Neuropsychological Evaluation

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
Medical records
School records
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 physical abuse.

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 more problems.

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 impaired.

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 impairment.

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:

Aggravating 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

Mitigating Circumstances:

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 participants.

The defendant acted under extreme duress or under substantial domination of another person.

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.


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 medications.

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 disturbance.

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 abuse.

K) Paul Scott had an impoverished upbringing.

L) Paul Scott was raised in a grossly dysfunctional family, with no stable living environment.

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
Professional Neuropsychology

Certified Addictions Specialist The ca