People v. Wetmore
22 Cal. 3d 318, 583 P.2d 1308, 149 Cal. Rptr. 265 (1978)
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Rule of Law:
Evidence of diminished mental capacity is admissible during the guilt phase of a trial to negate the specific intent element of a crime, even if that evidence also tends to prove the defendant was legally insane.
Facts:
- Joseph Cacciatore left his apartment for three days.
- During his absence, defendant Wetmore, who had a long history of psychotic illness, began to believe he owned property and was 'directed' to Cacciatore's apartment.
- Believing he owned the apartment, Wetmore broke the lock, entered, put on Cacciatore's clothes, cooked his food, and rearranged the furniture.
- When Cacciatore returned, he found Wetmore in the apartment and called the police.
- Police arrested Wetmore, who was shocked and embarrassed, only then understanding he did not own the apartment.
- Three psychiatric reports concluded that Wetmore entered the apartment under the delusion that he owned it and its contents.
Procedural Posture:
- Wetmore was charged with burglary in a California trial court.
- Wetmore pled not guilty and not guilty by reason of insanity.
- Both parties waived a jury trial and submitted the case to the judge on the preliminary hearing transcript and psychiatric reports.
- During the guilt phase, the trial court refused to consider the psychiatric reports for the issue of specific intent, reasoning they were only relevant to the issue of insanity.
- The trial court found Wetmore guilty of second-degree burglary.
- In the subsequent sanity phase, the court considered the psychiatric reports and found Wetmore not guilty by reason of insanity.
- The trial court then ordered Wetmore committed to a state hospital.
- Wetmore appealed the order of commitment to the Supreme Court of California.
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Issue:
Does a trial court err by refusing to consider evidence of a defendant's diminished mental capacity during the guilt phase of a trial to negate specific intent, on the grounds that such evidence also suggests the defendant was legally insane?
Opinions:
Majority - Tobriner, J.
Yes. A trial court errs by refusing to consider such evidence because a defendant cannot be logically or constitutionally denied the right to present probative evidence to rebut an element of the charged crime. The state bears the burden of proving every element of an offense, including specific intent. The court explicitly rejects the prior dictum from People v. Wells, which barred evidence tending to show insanity from the guilt phase. The court reasoned that the distinction between evidence showing a defendant 'did not' have the requisite intent versus evidence showing he 'could not' have it is illogical and unsupportable, as proof that something could not exist is the best evidence that it did not exist. Therefore, evidence of a defendant's mental condition is admissible to show he lacked the specific intent to commit the charged crime, regardless of whether that evidence might also persuade a trier of fact that the defendant is insane.
Analysis:
This decision effectively collapses the evidentiary wall between the defenses of diminished capacity and insanity in California's bifurcated trial system. By holding that evidence tending to prove insanity is admissible to negate specific intent in the guilt phase, the court eliminated the illogical distinction established in the People v. Wells dictum. This ruling significantly impacts trial strategy, allowing defendants to introduce the same psychiatric evidence in both the guilt and sanity phases, which the court notes makes the bifurcated trial system duplicative and inefficient. The decision also affirms that acquittal is the proper remedy if the state cannot prove specific intent, and suggests civil commitment, not criminal conviction, is the appropriate path for defendants who may still pose a danger to the public.
