Hendershott v. People
653 P.2d 385, 1982 Colo. LEXIS 697 (1982)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The constitutional principle of due process requires that a criminal defendant be permitted to introduce reliable and relevant evidence of a mental impairment to negate the requisite culpability element (mens rea) of any criminal charge, not just those requiring a specific intent.
Facts:
- Lee Roy Hendershott lived in a rooming house owned by Patricia Styskal, with whom he had an intermittent dating relationship.
- Problems developed due to Hendershott's excessive drinking, and on April 28, 1979, Styskal asked him to move out.
- After Styskal drove Hendershott to a friend's house, he returned to the rooming house later that evening, appeared intoxicated, and acted incoherently toward another boarder, Richard Jacobs.
- Hendershott chased and briefly struggled with Jacobs, who managed to flee.
- Around 11:00 p.m., Styskal returned home and found Hendershott waiting in her bedroom.
- Hendershott accused Styskal of being with another man and then struck, kicked, and choked her.
- Styskal was able to escape to a neighbor's home and summon the police.
- Police found Hendershott unconscious in an upstairs bedroom of Styskal's home.
Procedural Posture:
- Lee Roy Hendershott was charged with third-degree assault in Boulder County Court (trial court).
- Before trial, the prosecution filed a motion in limine to exclude expert testimony regarding Hendershott's mental condition of adult minimal brain dysfunction.
- The Boulder County Court granted the motion, ruling the evidence inadmissible as a matter of law for a general intent crime under its interpretation of section 18-1-803.
- Following a trial, a jury found Hendershott guilty of assault in the third degree.
- Hendershott, as appellant, appealed his conviction to the Boulder District Court (intermediate appellate court).
- The Boulder District Court affirmed the conviction, agreeing with the trial court's exclusion of the mental impairment evidence.
- The Supreme Court of Colorado granted certiorari to review the judgment of the Boulder District Court.
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 a state statute, as interpreted by the lower courts to prohibit a defendant from introducing evidence of an impaired mental condition to negate the culpability elements of 'knowingly' or 'recklessly' for a general intent crime, violate the Due Process Clauses of the United States and Colorado Constitutions?
Opinions:
Majority - Quinn, Justice
Yes, a statutory interpretation that precludes a defendant from presenting any mental impairment evidence to negate the requisite culpability for the crime charged violates due process of law. Due process requires the prosecution to prove every element of a crime beyond a reasonable doubt, including the defendant's mental state (mens rea). A defendant has a fundamental constitutional right to present witnesses and relevant evidence to contest the prosecution's case. Prohibiting a defendant from introducing evidence of a mental impairment that could show they did not act 'knowingly' or 'recklessly' renders the prosecution's evidence on that element uncontestable. This effectively creates an unconstitutional presumption of culpability, which violates the presumption of innocence and undermines the reasonable doubt standard. The state's policy arguments regarding the insanity defense and the reliability of psychiatric testimony do not justify infringing upon these fundamental constitutional protections. This right is distinct from the limited defense of self-induced intoxication, which involves moral culpability not present in a genuine mental impairment.
Analysis:
This decision significantly broadens a defendant's ability to challenge the mental element of a crime in Colorado. By grounding the admissibility of mental impairment evidence in the due process right to present a defense, the court prevents the legislature from statutorily limiting such evidence to only specific intent crimes. The ruling establishes that a state cannot create an evidentiary bar that relieves the prosecution of its burden to prove an essential element of the crime beyond a reasonable doubt. This precedent strengthens defendants' rights and requires courts to allow evidence of conditions like 'adult minimal brain dysfunction' to be considered by the jury when determining if the defendant possessed the necessary mental state for any offense.
