Fisher v. United States
328 U.S. 463, 66 S. Ct. 1318, 1946 U.S. LEXIS 2178 (1946)
Rule of Law:
In the District of Columbia, evidence of an accused's mental deficiency that falls short of legal insanity cannot be considered by a jury to negate the elements of deliberation and premeditation required for first-degree murder, as such a "partial responsibility" doctrine is a matter for legislative change or the discretion of local courts, not for the Supreme Court.
Facts:
- Catherine Cooper Reardon was a librarian at the Cathedral of Saint Peter and Saint Paul in Washington, D. C., where Robert Fisher was employed as a janitor.
- Miss Reardon had complained to the verger about Fisher's care of the premises a few days prior to the incident, and the verger had informed Fisher of the complaint.
- On March 1, 1944, Miss Reardon and Fisher were alone in the library when Miss Reardon confronted Fisher with insulting words regarding his work, including calling him a "black nigger."
- Fisher became angry and slapped Miss Reardon, who then ran away screaming.
- Fisher ran up a flight of steps towards an exit but turned back, seized a stick of firewood, and struck Miss Reardon, then choked her to silence when the stick broke.
- Fisher dragged Miss Reardon to a lavatory, and after cleaning up blood, returned when she started screaming again, stabbing her in the throat with a knife.
- After the stabbing, Fisher dragged Miss Reardon's body into an adjoining pump pit, where it was discovered the following morning.
Procedural Posture:
- Robert Fisher was indicted by the District Court of the United States for the District of Columbia for killing Catherine Cooper Reardon with deliberate and premeditated malice (first-degree murder).
- The District Court of the United States for the District of Columbia found Fisher guilty on the first count and imposed a death sentence.
- Fisher appealed the judgment and sentence to the United States Court of Appeals for the District of Columbia.
- The United States Court of Appeals for the District of Columbia affirmed the judgment and sentence of the District Court.
- The Supreme Court granted a writ of certiorari to review the case.
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Issue:
Does the District Court for the District of Columbia err by refusing to instruct a jury that evidence of an accused's psychopathic aggressive tendencies, low emotional response, and borderline mental deficiency, which do not amount to legal insanity, should be considered in determining whether the accused possessed the deliberation and premeditation necessary for first-degree murder?
Opinions:
Majority - Mr. Justice Reed
No, the District Court for the District of Columbia did not err by refusing to instruct the jury that evidence of the accused's mental deficiencies, short of legal insanity, should be considered in determining whether he possessed the deliberation and premeditation necessary for first-degree murder. The Court affirmed the lower courts, holding that it is the established law in the District of Columbia that an accused is not entitled to an instruction based on evidence of mental weakness, short of legal insanity, to reduce the crime from first to second-degree murder. The Court found that the separation of murder into degrees did not fundamentally alter the principle concerning mental capacity for malice as it relates to insanity, citing United States v. Lee. While acknowledging that some states have adopted a "partial responsibility" theory and recognizing the views of criminologists and psychologists, the Court stated that forcing the District to adopt such a rule would be a "fundamental change in the common law theory of responsibility." It deemed such a change more properly a subject for legislative action or the discretion of District courts, emphasizing its policy of non-interference with local rules of law in the District save for exceptional situations or egregious error, neither of which it found here given the "long established and deeply rooted" local law. The Court also distinguished Hopt v. People, noting it involved a statute specifically establishing a rule for intoxication, unlike the general mental deficiency at issue.
Dissenting - Mr. Justice Frankfurter
Yes, the trial court erred because the instructions failed to adequately guide the jury on the crucial issue of premeditation and deliberation, especially given the specific circumstances of the case and the legislative intent behind dividing murder into degrees. Justice Frankfurter argued that while the Court should not interpret facts independently, the jury, under proper guidance, might have found the absence of premeditation. He emphasized that the homicide, spurred by an "unhinging" insult ("black nigger"), appeared to be an "instinctive response to provocation" rather than a deliberate, premeditated act. He highlighted Fisher's low-grade mentality and his testimony suggesting his aim was merely to stop the screaming. The legislative division of murder into degrees, he contended, was meant to confine the death sentence to designed homicide, not instinctive reactions. He criticized the trial court's instructions as "threadbare generalities, a jumble of empty abstractions" that failed to bring the issue of premeditation "sharply and vividly to the jury’s mind," particularly in a capital case where life is at stake. He argued that the Court should exercise its supervisory responsibility over federal courts and not defer to the District's courts on such a fundamental issue of justice, especially when the local law cited (e.g., United States v. Lee) predated the statutory division of murder into degrees.
Dissenting - Mr. Justice Murphy
Yes, the District Court erred because mental deficiency not amounting to complete insanity should be considered by the jury in determining deliberation and premeditation, a principle supported by precedent and evolving scientific understanding. Justice Murphy asserted that the issue transcends local law, affecting criminal justice generally, and warrants full consideration, especially given the expanding knowledge of psychology and psychiatry. He cited Hopt v. People, 104 U.S. 631, which stated that a defendant's "condition of mind, by reason of drunkenness or otherwise," should be considered regarding premeditation, as precedent for allowing mental deficiency evidence. He argued that mental impairment short of total insanity is a scientifically established fact, and forcing juries to choose between a false premise of mental capacity for first-degree murder or complete acquittal is illogical and unjust. He advocated for adjudging individuals based on personal culpability and integrating scientific advancements, stating that Congress, by distinguishing murder degrees, implicitly requires courts to allow all relevant evidence on deliberation and premeditation. Justices Frankfurter and Rutledge joined in this dissent.
Dissenting - Mr. Justice Rutledge
Yes, the trial court erred in refusing the requested instruction on mental deficiency and by giving abstract instructions that failed to relate to the crucial issues of premeditation and deliberation. Justice Rutledge agreed with Justice Murphy that Congress's 1901 introduction of premeditation and deliberation requirements for first-degree murder was not intended to be limited to cases of intoxication. Therefore, he believed the defendant was entitled to the requested instruction or one of similar import concerning mental deficiency. He further agreed with Justice Frankfurter that, even if the instructions given were technically correct, they were "wholly abstract" and failed to adequately "point up the evidence, at least in broad outline, in relation to those issues" of premeditation and deliberation, which were crucial for a life-or-death decision. He concluded that the charge's deficiency, magnified by the abstract nature of the instructions, failed to meet the standard set by Congress.
Analysis:
This case represents a critical juncture in the development of criminal law regarding mental state and culpability. By affirming the long-standing "all or nothing" approach to insanity in the District of Columbia, the Supreme Court largely rejected the emergent doctrine of "diminished capacity" or "partial responsibility." This decision maintained a bright-line distinction between legal insanity (which fully exculpates) and all other mental states (which do not reduce the degree of crime). The ruling underscored judicial deference to legislative bodies and local courts on matters of criminal law reform, especially when such reforms involve significant departures from common law principles, even in the face of evolving scientific understanding of mental health. Future efforts to incorporate nuanced understandings of mental illness into criminal culpability would primarily need to proceed through legislative action or state-level judicial innovation rather than broad federal constitutional mandate.
