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Law School Case Brief

Smith v. State - 614 P.2d 300 (Alaska 1980)

Rule:

The defense must come forth with some evidence supporting the defense of insanity before the burden of proof shifts to the state. The "some evidence" test requires that there be more than a scintilla, but less than that which would compel a reasonable doubt as a matter of law. 

Facts:

Defendant, an army private, commandeered a vehicle at gunpoint, and after being chased by police shot and seriously wounded a police officer. At trial, the only defense was that defendant was innocent by reason of insanity. Evidence from two psychiatrists and one psychologist was not in agreement. All of the evidence pointed to a finding that defendant had the capacity to appreciate the wrongfulness of his conduct. The trial court found that defendant was sane beyond a reasonable doubt pursuant to Alaska Stat. § 12.45.083(a),(b)(act). On appeal, defendant argued that the trial court lacked sufficient evidence to find him sane beyond a reasonable doubt. The state supreme court affirmed defendant's conviction for shooting with intent to kill, wound or maim.

Issue:

Could defendant invoke insanity as a defense to avoid responsibility from shooting a police officer?

Answer:

No.

Conclusion:

Pursuant to the act, defendant was not responsible, if at the time of the conduct, as a result of mental disease or defect, he lacked substantial capacity either to appreciate the wrongfulness of his conduct or to conform his conduct to the requirements of law. All of the evidence pointed to a finding that defendant had the capacity to appreciate the wrongfulness of his conduct, so that the focus of review was on whether he had substantial capacity to conform his conduct to the requirements of the law. The trial court could have been persuaded that the testimony of the prosecution expert was most compelling and that defendant was sane beyond a reasonable doubt.

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