Brief Fact Summary. The Defendant, Steven Green (Defendant), shot and killed the victim, Officer Harry Wilcox (the victim). The Defendant was convicted by a jury of murder, but on appeal, his conviction was set aside due to the Defendant’s insanity at the time of the murder.
Synopsis of Rule of Law. Where the prosecution has the burden of proving the defendant’s sanity beyond a reasonable doubt, that burden can only be met through expert testimony, lay testimony when the proper foundation has been laid, or a showing of acts or statements of the defendant made at or near the time of the commission of the crime.
When a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile.View Full Point of Law
Issue. Is the prosecution’s introduction of only lay testimony sufficient to carry its burden of proving the Defendant’s sanity beyond a reasonable doubt?
Held. No. The Defendant introduced substantial lay and expert witness testimony to prove his insanity at the time of the killing. By rebutting the Defendant’s expert testimony with no more than lay witnesses, the prosecution failed to meet its heavy burden of proving sanity.
Discussion. While not a per se rule, the Court of Criminal Appeals of Tennessee seems to caution that a lack of expert testimony will substantially undermine the prosecution’s ability to prove sanity beyond a reasonable doubt.