State v. Necaise
466 So. 2d 660 (1985)
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Rule of Law:
Under Louisiana law, expert psychiatric testimony regarding a mental condition, such as 'battered woman syndrome,' is inadmissible to negate the specific intent required for an offense when the defendant has entered a plea of 'not guilty.' Such evidence is only admissible if the defendant pleads 'not guilty by reason of insanity.'
Facts:
- Cecelia J. Necaise had a documented history of being physically abused by her husband, George Necaise.
- On the evening of February 19, 1983, George Necaise physically assaulted Cecelia, held a knife to her throat, threatened to kill her, and kicked her in the back.
- George then forced Cecelia to engage in sexual relations at knifepoint.
- After the assault, George forced Cecelia to lie in bed next to him and told her, "I want you to wonder what minute I'm going to cut your throat."
- Fearing for her life, Cecelia retrieved a gun from beneath the mattress as she eased out of bed.
- Cecelia testified that when she heard movement and saw her husband raising up with a clenched fist, she panicked and shot him.
- George Necaise died from five gunshot wounds: three to his left back and two to the back of his head.
Procedural Posture:
- Cecelia J. Necaise was indicted for manslaughter in connection with the death of her husband, George Necaise.
- At trial in the court of first instance, Necaise entered a plea of not guilty and asserted the affirmative defense of self-defense.
- A twelve-person jury convicted Necaise of manslaughter.
- The trial court sentenced her to twelve years at hard labor.
- Necaise, as appellant, appealed her conviction and sentence to the Court of Appeal of Louisiana, Fifth Circuit, with the State of Louisiana as the appellee.
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Issue:
Does Louisiana law, which bars evidence of a mental defect for a defendant who pleads 'not guilty,' prohibit the admission of expert testimony on 'battered woman syndrome' offered to show the defendant's state of mind and lack of specific intent?
Opinions:
Majority - Bowes, Judge
Yes, Louisiana law prohibits the admission of expert testimony on 'battered woman syndrome' when offered to negate criminal intent under a 'not guilty' plea. Louisiana's criminal procedure precludes the admission of evidence concerning a mental defect or condition unless the defendant pleads 'not guilty by reason of insanity.' The court reasoned that allowing such testimony would effectively introduce a 'partial responsibility' or 'diminished capacity' defense, which has been consistently rejected in Louisiana jurisprudence. The state adheres to an 'all or nothing' approach, meaning a defendant is either legally sane and fully responsible or legally insane and not responsible. Citing precedent like State v. Edwards and State v. LeCompte, the court affirmed that a mental disorder short of insanity cannot serve to negate specific intent, and therefore the trial court correctly excluded the psychiatrist's testimony.
Analysis:
This decision solidifies Louisiana's strict position against the diminished capacity defense, reinforcing a significant procedural hurdle for defendants suffering from conditions like Battered Woman Syndrome. By precluding expert testimony on a defendant's mental state absent an insanity plea, the ruling limits the ability to present a complete picture of the defendant's subjective perception of danger, which is central to a self-defense claim. The case forces defendants in similar situations into a difficult choice: either forgo crucial psychological evidence or adopt an 'all-or-nothing' insanity defense, which may not accurately reflect their mental state. This holding contrasts with jurisdictions that allow such expert testimony to help a jury understand the reasonableness of a defendant's actions from their perspective.
