State v. Perry
502 So. 2d 543 (1986)
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Rule of Law:
A confession made by a defendant with a diagnosed mental illness is not automatically rendered involuntary and inadmissible. If the evidence, under the totality of the circumstances, shows the defendant was lucid, aware of their rights, and not experiencing a psychotic episode at the time the statement was given, the confession may be deemed voluntary.
Facts:
- Michael Owen Perry had a poor relationship with his parents, Grace and Chester Perry, who had previously had him committed to a mental hospital and did not allow him in their home without permission.
- On July 17, 1983, Perry entered a nearby house and shot and killed his cousins, Randy Perry and Bryan LeBlanc, as they slept.
- Perry then broke into his parents' home, waited for them to return from a trip, and upon their arrival, shot and killed his father, mother, and two-year-old nephew, Anthony Bonin.
- To ensure their deaths, Perry shot his parents and the child a second time in the head.
- After the killings, Perry took $3,000 from his father's wallet and a strongbox belonging to his mother, then fled in his father's car to Washington, D.C.
- On July 31, 1983, police in Washington, D.C. were called to a hotel regarding a dispute Perry had with another guest over a radio.
- A routine check on Perry revealed he was wanted in Louisiana for five counts of homicide, leading to his arrest.
- A subsequent search of Perry's hotel room revealed a television set with the names of the five victims written on its side.
Procedural Posture:
- Michael Owen Perry was indicted in a Louisiana trial court on five counts of first degree murder.
- Perry initially entered a dual plea of 'not guilty and not guilty by reason of insanity.'
- Following a sanity hearing and psychiatric evaluation at Feliciana Forensic Facility, the trial court found Perry competent to stand trial.
- Over the objection of his counsel, the trial court permitted Perry to withdraw his insanity plea and enter a single plea of 'not guilty.'
- A jury in the trial court found Perry guilty as charged on all five counts.
- After a separate sentencing phase, the same jury unanimously recommended that Perry be sentenced to death on each count.
- The trial judge imposed the death sentence, and Perry (defendant-appellant) directly appealed his conviction and sentence to the Supreme Court of Louisiana, with the State of Louisiana as plaintiff-appellee.
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Issue:
Does a defendant's mental illness, specifically a diagnosis of paranoid schizophrenia, automatically render a confession involuntary and inadmissible if the defendant appears alert, responsive, and aware during the confession?
Opinions:
Majority - Cole, Justice
No. A defendant's mental illness does not automatically render a confession involuntary. The court found that the evidence supported the trial judge's determination that Perry's confession to Deputy Durkes was admissible. The State has the burden to show a confession was made freely and voluntarily, which it did here. Although Perry had been diagnosed as a paranoid schizophrenic, the testimony indicated that he was often lucid and that his psychotic episodes were triggered by specific words not present during the confession. Durkes testified that Perry initiated the confession, was read his Miranda rights which he waived, and appeared alert, responsive, and made eye contact throughout. The court distinguished this case from State v. Glover, where the defendant also suffered from mental retardation and organic brain damage, finding it more analogous to State v. West, where a confession from a paranoid schizophrenic was upheld. Therefore, considering the totality of the circumstances, Perry's mental condition did not rise to a level that would negate the voluntariness of his statement.
Analysis:
This case clarifies the standard for the admissibility of confessions from defendants with significant mental illness. It reinforces the principle that a clinical diagnosis alone, even one as serious as paranoid schizophrenia, is not a per se bar to a finding of voluntariness. The decision emphasizes a fact-intensive, case-by-case analysis that focuses on the defendant's actual state of mind and coherence at the time of the confession, rather than solely on a general diagnosis. This precedent provides guidance for lower courts, allowing them to admit confessions from mentally ill individuals so long as the prosecution can sufficiently prove lucidity and a valid waiver of rights during the custodial interrogation.
