United States v. Roland Arthur Edwards
1987 U.S. App. LEXIS 7628, 23 Fed. R. Serv. 452, 819 F.2d 262 (1987)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under Federal Rule of Evidence 704(b), an expert witness may testify fully about a defendant's diagnosis, mental state, and motivation, but may not state an opinion or inference as to whether the defendant had the ultimate mental state constituting an element of the crime or a defense thereto.
Facts:
- Roland Edwards was experiencing significant financial problems, including pressure from the I.R.S.
- On April 30, 1984, Edwards entered a bank in Naples, Florida, and handed a teller a legible, handwritten note demanding money.
- Edwards told the teller that he had worked in a bank, knew what he was doing, and warned her not to do anything.
- He carried a bag containing a bulky L-shaped object, handling it in a way that made the teller believe it was a gun.
- Edwards left the bank with $2,040, sprinted to a pick-up truck with 'Edwards Construction' on the side, and sped away.
- Shortly after, Edwards' ex-wife contacted him via a beeper he carried.
- In a return call urged by his ex-wife, Edwards admitted that he had 'robbed a bank.'
Procedural Posture:
- Roland Edwards was charged with unarmed bank robbery under 18 U.S.C. § 2113(a) in a federal district court.
- Edwards entered a plea of not guilty by reason of insanity.
- Following a two-day trial, a jury found Edwards guilty.
- Edwards, as the appellant, appealed his conviction to the U.S. Court of Appeals for the Eleventh Circuit, with the United States as the appellee.
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 an expert psychiatrist's testimony that a defendant's frantic actions in response to a financial crisis were 'understandable' violate Federal Rule of Evidence 704(b)'s prohibition on expert opinion regarding an ultimate issue of the defendant's mental state?
Opinions:
Majority - Vance, J.
No. The expert testimony did not violate Federal Rule of Evidence 704(b) because it did not state a conclusion on the ultimate legal issue of Edwards' sanity. The court reasoned that Rule 704(b) was enacted to prevent experts from making 'leaps in logic' from medical concepts to legal conclusions, not to limit the flow of relevant diagnostic and clinical information to the jury. Dr. Jaslow's testimony that Edwards' frantic behavior was 'understandable' in light of his financial crisis was a permissible, common-sense generalization used to rebut the defense expert's diagnosis of a manic state. This testimony explained Edwards' mental state and motivation without opining on whether he lacked the substantial capacity to appreciate the wrongfulness of his conduct, which is the ultimate issue for the jury alone to decide.
Analysis:
This decision clarifies the scope of the then-recent Federal Rule of Evidence 704(b), establishing a crucial boundary for expert testimony in insanity defense cases. It affirms that while experts are barred from giving conclusory opinions on the ultimate legal issue of sanity, they retain broad latitude to testify about the defendant's diagnosis, mental state, and motivations. The ruling guides courts and practitioners in distinguishing between permissible background and diagnostic information that helps the jury understand the defendant's condition and impermissible testimony that usurps the jury's role as the ultimate finder of fact on the legal question of insanity.
