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Ruffin v. State

Citation. 270 S.W.3d 586 (Tex. Crim. App. 2008)
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Brief Fact Summary.

Ruffin appealed a first-degree aggravated assault conviction claiming that mental illness negates the requisite state of mind in intentional crimes.

Synopsis of Rule of Law.

An intentional crime is committed if the culprit is aware of the consequences of his actions as he is performing them.

Facts.

Ruffin was charged with first-degree aggravated assault after shooting several gunshots on his property. Ruffin was convicted on the aggravated assault charge after several witnesses and expert testimony revealed Ruffin’s deteriorating mental health. The appellate court affirmed Ruffin’s conviction.

Issue.

Whether a mentally ill person can commit an intentional crime?

Held.

Yes. The judgment against Ruffin is overturned. Ruffin’s deteriorating mental state led him to believe that he was shooting at Muslims rather than police officers. Ruffin does not fulfill the intent of the crime because his intent was not to shoot at police officers.

Discussion.

An intentional crime occurs if a perpetrator intended the consequences of his actions. If a person performs an action with different intents than the crime committed, the charged person cannot be convicted of the crime.


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