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Name: People v. Marsh
Case #: C078999
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 02/22/2018

Due process and the prohibition against disproportionate punishment did not require trial court to instruct on irresistible impulse as the standard for sanity of a juvenile offender. Marsh, a juvenile offender, was found guilty of two counts of first degree murder. After often expressing a desire to kill, he randomly selected a home in the middle of the night and stabbed an elderly couple to death, mutilating their bodies. He was found sane following the sanity phase of the trial. On appeal, he argued that due process and the prohibition against disproportionate punishment required the trial court to…

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Name: People v. McCarrick
Case #: A136822
Court: CA Court of Appeal
District 1 DCA
Opinion Date: 11/30/2016

Trial court's failure to add "delusion" to jury instructions regarding the effect of hallucinations on defendant's ability to premeditate and deliberate was not error. Defendant pleaded not guilty and not guilty by reason of insanity to killing her three-year-old twin daughters. She claimed she suffered from delusional beliefs that killing the children was the only way to save them from being kidnapped and enslaved. In the guilt phase she was found guilty of two counts of first degree murder with special circumstances. In the sanity phase of the trial, the jury found the defendant sane at the time of the…

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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

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…

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Name: People v. Mills
Case #: S191934
Court: CA Supreme Court
District CalSup
Opinion Date: 10/18/2012

The question of a defendant's sanity is irrelevant at the guilt phase of a bifurcated trial under Penal Code section 1026 and, as a result, the court should not instruct the jury on the subject. Mills was charged with murder. He pleaded not guilty and raised an insanity defense. During the guilt phase trial, the defense presented evidence of Mills' mental illness in an attempt to prove "imperfect" self-defense. Over defense objection, the trial court instructed the jury that Mills was conclusively presumed to have been sane at the time of the offense. In his appeal from his subsequent murder…

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Name: People v. Chavez
Case #: B185907
Court: CA Court of Appeal
District 2 DCA
Division: 1
Opinion Date: 03/04/2008

A defendant acquitted by reason of insanity on certain crimes must first be committed to a state hospital before he can be transferred to state prison. Chavez committed two separate sets of offenses, and was convicted of all the counts arising from them. The jury found that Chavez was insane at the time he committed the offenses in April, but sane at the time he committed the offenses in November. He was sentenced to a total term of 20 years in state prison and 16 years commitment to a state mental hospital to be served after the…

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Name: Stark v. Hickman
Case #: 03-17241
Court: US Court of Appeals
District 9 Cir
Opinion Date: 08/01/2006

A habeas petitioner's due process rights were violated when the trial court charged the jury that the petitioner was presumed to be "conclusively sane." At his murder trial, the defendant had pleaded not guilty and not guilty by reason of insanity. At the conclusion of the guilty phase, the court told the jury that it should presume that the defendant was "conclusively sane." The jury found the defendant guilty, and subsequently found him to have been legally sane at the time of the offense. The Ninth Circuit found that the defendant was entitled to habeas relief,…

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Name: People v. Jantz
Case #: B175147
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 03/27/2006

The court erred when it failed to give a limiting instruction regarding a defendant’s statements to experts concerning his judgment. On appeal from a murder conviction, the defendant argued that the court should have instructed the jury at his sanity trial that it could consider his statements to a mental health expert only to show the basis of the expert’s opinion and not for their truth. The Court of Appeal agreed, but found that the error concerned only the instruction and not the admission of the evidence, and that it was harmless beyond a reasonable doubt. The…

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Name: People v. Severance
Case #: C048410
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/05/2006

The trial court had the power to direct a verdict of sanity where there was no substantial evidence that the offender was insane at the time of the offense. After first rejecting the People’s argument of forfeiture because it would have been futile for appellant to have argued in the trial court that the court lacked the power to direct a verdict of sanity, the appellate court adopted the holding in People v. Ceja (2003) 106 Cal.App.4th 1071, which held that trial courts have an inherent power to remove an insanity defense from the jury when there is no…

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Name: People v. Ferris
Case #: F045368
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 06/27/2005

Appellant was convicted of multiple felonies, and was found sane at the time he committed the crimes. On appeal, he claimed that Apprendi impliedly altered the burden of proof on the question of insanity, now requiring the prosecution to prove sanity beyond a reasonable doubt. The appellate court rejected the argument. Sanity is not an element of the offense charged; the question is one of insanity as a defense. A finding of sanity does not increase the maximum penalty one can receive. Neither Apprendi nor Ring in any way impliedly overrules decisions holding that insanity…

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Name: People v. Torres
Case #: B163612
Court: CA Court of Appeal
District 2 DCA
Division: 1
Opinion Date: 03/30/2005

At the sanity phase of his (second) trial, the court instructed the jury pursuant to CALJIC 4.00 on the definition of insanity, but modified the instruction by adding language further defining the word "wrong" to include both legal and moral wrongs, as defined by "society's generally accepted standards." The appellate court found error and reversed. As modified, the instruction required the defendant to meet the burden of proving he was incapable of distinguishing right from both moral and legal wrong at the time he committed the crimes. Appellant was prejudiced by the error because his statements afterwards…

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