Smith v. State

Brief Fact Summary.

Expert testimony at Smith’s (Defendant) trial stated that he was schizophrenic and legally insane, but Defendant was found legally sane and convicted.

Synopsis of Rule of Law.

A defendant can be found legally sane even when the preponderance of the medical expert testimony at trial says otherwise.

Facts.

Defendant was a soldier who was in the process of being dishonorably discharged from the Army due to misbehavior. He stole an Army vehicle at gunpoint and fled the base. He was chased by police into the woods where he was eventually captured. During the chase, Defendant shot and wounded one of the pursuers. Defendant was charged with shooting with intent to kill or cause great bodily harm. At trial, evidence was admitted of Defendant’s history of strange behavior. Two defense experts testified that Defendant suffered from chronic schizophrenia and was legally insane at the time of the crime. A government expert testified that Defendant was schizophrenic, but not legally insane at the time of the crime. The judge, acting as factfinder, found Defendant legally sane and convicted him. Defendant appealed.

Issue.

Can a defendant be found legally sane when the preponderance of the medical expert testimony at trial says otherwise?

Held.

[Judge not named in casebook extract.] Yes. A defendant can be found legally sane even when the preponderance of the medical expert testimony at trial says otherwise.Alaska law places the burden of producing substantial evidence of insanity on the defendant. When that burden is met, the burden then shifts to the government to disprove insanity beyond a reasonable doubt. The rule does not require that conflicting expert testimony on the matter be resolved in favor of the defendant. The fact-finder is free to believe one party’s expert and not the other’s, even when the other side has more experts. Here, the State’s expert convinced the judge beyond a reasonable doubt that Defendant was not legally insane at the time of the crime. This was not clear error. Affirmed.

Dissent.

(Boochever, J.) The State did not carry its burden to disprove insanity beyond a reasonable doubt. Defendant lacked the capacity to conform his conduct to societal standards.

Discussion.

Alaska’s insanity test has two-parts. A defendant can invoke the defense if 1) he was unable to appreciate the wrongfulness of his conduct at the time of the offense, or 2) he was incapable of conforming his conduct to societal norms at the time of the offense. In this case, both parties conceded that the first prong did not apply. There are many factors that would lead a fact-finder to find one expert more credible than another, such as depth of experience and history of testifying as a paid expert witness.