Blake v. United States
407 F.2d 908 (1969)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A person is not responsible for criminal conduct if, at the time of such conduct, as a result of a mental disease or defect, they lack substantial capacity either to appreciate the wrongfulness of their conduct or to conform their conduct to the requirements of law.
Facts:
- Beginning in 1944 while in the Navy, Blake had a long and documented history of mental illness, including an epileptic seizure that led to a medical discharge.
- Over the next two decades, Blake received multiple rounds of electro-shock treatment and was repeatedly hospitalized in various private psychiatric institutions.
- In 1956, a court adjudged Blake legally incompetent and placed him under his father's guardianship.
- Blake's adult life was characterized by heavy drinking, use of stimulants and drugs, irrational acts, and disciplinary problems.
- On December 6, 1965, shortly after being released from prison for a probation violation, Blake robbed a bank.
- Blake claimed the bank he robbed was part of a group that had mishandled a trust fund established for him, and his dispute with the bank had been ongoing and bitter.
- Just before the robbery, Blake told a waitress he might rob a bank to get a large sum of money.
Procedural Posture:
- Blake was charged with bank robbery under 18 U.S.C.A. § 2113 in a United States District Court.
- At trial, Blake's principal defense was insanity at the time of the offense.
- The trial court instructed the jury using the existing 'Davis' standard for legal insanity.
- A jury found Blake guilty of bank robbery.
- The district court denied Blake's motion for a new trial and sentenced him.
- Blake appealed his conviction to the United States Court of Appeals for the Fifth Circuit.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the traditional Davis standard for the insanity defense, which requires a complete inability to distinguish right from wrong or a will that is 'completely destroyed,' remain the appropriate test for criminal responsibility, or should it be replaced by the American Law Institute's Model Penal Code test, which requires only a lack of 'substantial capacity'?
Opinions:
Majority - Bell, Circuit Judge
No, the Davis standard is an outmoded and unduly restrictive test for insanity that should be replaced. The court adopts the American Law Institute's (ALI) Model Penal Code standard, which provides that a person is not responsible for criminal conduct if, as a result of mental disease or defect, they lack 'substantial capacity' to appreciate the wrongfulness of their conduct or to conform their conduct to the law. The Davis standard's requirement of a 'complete' lack of mental capacity is an unrealistic absolute that does not align with modern psychiatric understanding of mental illness, which recognizes gradations of impairment. The ALI 'substantiality' test is a more adequate standard that allows a jury to consider evidence that a defendant suffered from a severe mental disease that impaired their control, even if their will was not 'completely destroyed.' The court exercises its supervisory power to adopt this new, uniform standard for the circuit to better enable courts and juries to give effect to the insanity defense in light of current medical knowledge.
Analysis:
This landmark decision officially abandoned the long-standing, restrictive M'Naghten-based rule for insanity (the Davis standard) in the Fifth Circuit and replaced it with the more modern and widely-adopted ALI Model Penal Code test. This shift significantly broadened the scope of the insanity defense, moving from a rigid requirement of total incapacity to a more flexible standard of 'substantial' incapacity. The ruling aligned the Fifth Circuit with a growing majority of other federal circuits and reflected a major legal trend of incorporating contemporary psychiatric principles into criminal law. This precedent made the insanity defense a more viable option for defendants with severe mental illnesses that did not necessarily render them completely unaware of their actions.
Unlock the full brief for Blake v. United States