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Name: People v. Blakely
Case #: D066381
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 10/16/2014
Summary

Trial court properly directed a verdict of sanity because defendant failed to present sufficient evidence for the jury to reasonably conclude he was incapable of distinguishing right from wrong when he robbed the victim, who he believed was a demon. After seeing Lamar with cash at a supermarket, Blakely attacked and robbed him in the parking lot. He pled not guilty by reason of insanity to assault with a deadly weapon and robbery. A jury found him guilty of both offenses and that he had suffered prior strikes. At the sanity phase of the trial, Blakely presented evidence that he suffers from paranoid schizophrenia. On the day of the offense, he thought Lamar was a demon based on hallucinations and voices in his head. After both sides presented their evidence, the court granted the People’s motion for a directed verdict of sanity. On appeal, Blakely challenged this ruling. Held: Affirmed. At his sanity trial, Blakely had the burden to present sufficient evidence for a jury to reasonably conclude that, based on a mental disease or defect, he was incapable of (1) knowing or understanding the nature and quality of his acts; or (2) distinguishing right from wrong when he assaulted and robbed Lamar. He only attempted to establish the second element. Although Blakely presented evidence that he suffers from paranoid schizophrenia, there was no evidence about what he believed or did not believe was morally correct at the time he attacked Lamar. The court disagreed with Blakely’s claim that his insane delusion that Lamar was a demon rendered him incapable of distinguishing right from wrong. Even if Blakely believed Lamar was a demon, there was no evidence in the record that he believed it was morally acceptable to attack Lamar and take his money.