State v. Armstrong
671 So.2d 307, 1996 WL 161784 (1996)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
An appellate court may overturn a jury's rejection of an insanity defense if the evidence of insanity so clearly preponderates in the defendant's favor that a rational juror could not have concluded the defendant failed to prove his insanity by a preponderance of the evidence.
Facts:
- Freddie Armstrong had a twenty-five-year history of paranoid schizophrenia, resulting in numerous involuntary hospitalizations.
- Just eleven days before the killing, Armstrong was involuntarily committed to a psychiatric hospital, noted as being psychotic, suicidal, and dangerous; he was released three days before the killing.
- On January 24, 1992, Armstrong went to a mortuary, left, and returned with a briefcase containing a large butcher knife.
- Inside the mortuary, Armstrong attacked and stabbed Rev. Fred Neal more than twenty times.
- When police officers arrived, Armstrong ignored their commands and, in their presence, severed Rev. Neal's head from his body.
- Armstrong then grinned, held the severed head up for the officers to see, placed the headless body in a chair, and dropped the head in a toilet.
- Armstrong later stated he believed Rev. Neal was the anti-Christ and he decapitated him to prove that, as an anti-Christ, Rev. Neal would not bleed.
- During the incident, officers described Armstrong as non-responsive and appearing to be 'a person possessed' or 'in a trance'.
Procedural Posture:
- The trial court appointed a sanity commission and, after a hearing, found Freddie Armstrong incompetent to proceed to trial and ordered him institutionalized.
- Approximately three months later, the trial court held another hearing and found Armstrong had regained the capacity to proceed.
- Armstrong was arraigned in state district court, pleading not guilty and not guilty by reason of insanity to the charge of second-degree murder.
- Following a jury trial, the jury rejected the insanity defense and returned a verdict of guilty.
- Armstrong appealed his conviction to the Louisiana Court of Appeal, Third Circuit, which affirmed the conviction, holding that a rational jury could have found he failed to prove his insanity.
- The Supreme Court of Louisiana granted certiorari to review the appellate court's decision on the insanity issue.
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 defendant with a long history of paranoid schizophrenia prove legal insanity by a preponderance of the evidence when the overwhelming majority of expert and lay testimony, coupled with the bizarre and public nature of the homicide, indicates he was incapable of distinguishing right from wrong at the time of the offense?
Opinions:
Majority - Lemmon, J.
Yes. A defendant proves legal insanity by a preponderance of the evidence where the totality of the circumstances, including a long history of severe mental illness, overwhelming expert opinion, and the public and bizarre nature of the act itself, demonstrates an incapacity to distinguish right from wrong. The court found the evidence of insanity clearly preponderated in Armstrong's favor. The combination of his twenty-five-year documented history of paranoid schizophrenia, his recent involuntary commitment for a psychotic episode, the testimony of four out of five psychiatric and psychological experts concluding he was insane, and the sheer bizarreness of the crime (decapitating the victim in front of armed police) was overwhelming. The court reasoned that conducting such a grotesque act in plain view of law enforcement is a significant indicator of an inability to distinguish right from wrong. A rational juror, viewing this evidence, could not have reached a contrary decision.
Dissenting - Kimball, J.
No. A rational trier of fact could have concluded the defendant failed to prove his insanity by a preponderance of the evidence, and the jury's determination should not be overturned. The dissent argued for deference to the jury's role as the fact-finder responsible for weighing evidence. It emphasized that the medical testimony was contradictory, as one expert, Dr. Murphy, opined that Armstrong was legally sane at the time of the offense. Furthermore, there was testimony that Armstrong acknowledged hearing a voice during the attack telling him his actions were wrong and had considered not killing the victim. Because rational jurors could disagree on the interpretation of this conflicting evidence, the appellate court should adopt the view most favorable to the prosecution and affirm the jury's verdict.
Analysis:
This case is significant because it illustrates the high but not insurmountable burden for an appellate court to reverse a jury's finding on the factual issue of insanity. While appellate courts are extremely deferential to jury verdicts, this decision establishes that such deference has limits. The court's ruling demonstrates that when evidence of legal insanity—particularly objective evidence like a long medical history and the public, bizarre nature of the crime—is truly overwhelming, a conviction may be overturned as irrational. It serves as a check on jury discretion in cases involving severe mental illness, suggesting that a single contrary expert opinion may be insufficient to sustain a verdict against a mountain of compelling evidence to the contrary.
Unlock the full brief for State v. Armstrong