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State v. Guido

    Citation. 283 Fed. Appx. 984 (3d Cir. 2008) [2008 BL 284236]

    Brief Fact Summary. The Appellant, Guido (Appellant), was convicted of second degree murder for killing her husband. The Appellant was subjected to physical and emotional abuse by her husband and was generally afraid of him. Defense counsel debated with expert witnesses over their reports pertaining to the interpretation of “disease of the mind” as it relates to the definition of legal insanity. During the trial, prosecutors alleged that defense counsel persuaded the expert witnesses to change their reports in order to obtain a more favorable outcome for his client.

    Synopsis of Rule of Law. Although the main emphasis for what constitutes a “disease of the mind” under M’Naghten concerns the actual state of mind, there is no concrete definition and the definition of legal insanity is up for debate.


    Facts. The victim in this case was the Appellant’s husband. The Appellant’s husband was a professional fighter who married her at a young age. The Appellant was intimidated by her husband and felt as though she were under a constant threat of injury. There was evidence of a few instances of actual injury. The victim had an extra-marital affair and as a result, the Appellant wanted a divorce. The Appellant called the police on several occasions prior to the incident to express her fear of the victim. On the night in question, the Appellant’s husband was asleep on the couch. The Appellant took a gun from the living room into the bedroom in order to commit suicide. Once in the bedroom, she changed her mind and decided to put the gun away. When the Appellant saw her husband lying on the couch, she opened fire until no bullets were left in the gun. Defense counsel hired expert witnesses in order to put together an insanity defense. The psychiatrists’ initial report stated that the Appella
    nt was legally sane at the time of the incident. After three hours of debate with defense counsel, the psychiatrists agreed to change their opinion as to the legal sanity issue. However, their underlying medical findings remained the same. During the jury trial, prosecutors somehow found out about the lengthy discussion between defense counsel and the expert witnesses. The prosecution informed the judge and defense counsel was ordered to give the prosecution a copy of the original report. Thereafter, the prosecution was allowed to argue this issue to the jury in an attacking manner.

    Issue. What constitutes “a disease of the mind” under the concept of legal insanity?

    Held. Judgment of the lower court is reversed. Chief Judge C.J. Weintraub delivered the opinion of the court. When the issue surrounding the change in the expert witnesses’ report was investigated, the change was decidedly made in all honesty. There was a debate over what the doctors understood to be the definition of “disease of the mind” under M’Naghten. The doctors thought it meant psychosis and not a lesser illness or aberration of the mind. While their prior medical findings remained the same, there was a change in the witnesses’ understanding of what the law means by “disease.” Ultimately, the doctors concluded they had too narrow a view of M’Naghten. Therefore, they concluded that Appellant’s diagnosed “anxiety neurosis” qualified as a disease within the legal rule.

    Discussion. There is a widespread reluctance to define what is meant by “disease” under the M’Naghten rule. Because there is no concrete definition, the definition of what constitutes legal insanity is up for discussion.

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