Polmatier v. Russ

Conn: Supreme Court
206 Conn. 229, 537 A. 2d 468 (1988)

ELI5:

Rule of Law:

A person who is legally insane is civilly liable for an intentional tort. The intent required is the intent to perform the physical act, not a rational intent to cause harm, and such intent is not negated by irrational motives or delusions.

Facts:

Norman Russ visited the home of his father-in-law, Arthur Polmatier.
During the visit, Russ was seen astride Polmatier on a couch, beating him on the head with a beer bottle.
Russ then went into a bedroom, retrieved a rifle and a box of ammunition.
Russ returned to the living room and shot Polmatier twice, causing his death.
About five hours later, Russ was found naked in a wooded area, holding his infant daughter.
A psychiatrist testified that at the time of the killing, Russ was suffering from a severe case of paranoid schizophrenia and was legally insane, experiencing delusions that Polmatier was a spy.

Procedural Posture:

Norman Russ was prosecuted criminally for murder but was found not guilty by reason of insanity.
Dorothy Polmatier, as executrix of Arthur Polmatier's estate, filed a civil lawsuit against Russ in a Connecticut state trial court for wrongful death.
Russ raised a special defense, arguing that he was insane at the time of the killing and therefore could not have formed the intent necessary for tort liability.
Following a trial to the court, the trial court found in favor of the plaintiff, Polmatier, and awarded compensatory damages.
Russ, as the appellant, appealed the trial court's judgment to the Connecticut Supreme Court.

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Issue:

Does a defendant's insanity, which prevents them from forming a rational motive, relieve them from civil liability for an intentional tort?

Opinions:

Majority - Glass, J.

No. A defendant's insanity does not relieve them from civil liability for an intentional tort. The court adopted the majority rule holding that insane persons are liable for their torts for several public policy reasons: 1) where one of two innocent persons must suffer a loss, it should be borne by the one who caused it; 2) liability encourages custodians of the insane person to provide proper care and restraint; and 3) it prevents tortfeasors from feigning insanity to escape liability. The court distinguished the intent required for a civil tort from that required for a criminal conviction. For civil liability, the actor only needs to intend the physical act, even if the motives for that act are irrational or based on delusions. The court found that Russ's actions were voluntary and intentional physical movements (an 'act'), and his statements that he wanted to kill Polmatier demonstrated he intended the consequences of that act, even if his reasons were delusional.

Analysis:

This decision formally aligns Connecticut with the majority of U.S. jurisdictions on the issue of tort liability for mentally ill individuals. It reinforces a fundamental distinction between criminal law, which focuses on moral culpability and mental state (mens rea), and tort law, which prioritizes compensating victims for their injuries. By establishing an objective standard for 'intent' in this context—focusing on the intent to commit the physical act rather than the sanity of the motive—the court ensures that a victim's ability to recover damages does not depend on the tortfeasor's subjective mental state. This precedent solidifies the principle that compensation for the injured party is paramount, even when the person causing the harm is not morally blameworthy.

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