Law School Case Brief
State v. Wilson - 242 Conn. 605, 700 A.2d 633 (1997)
Under Connecticut's insanity statute, Conn. Gen. Stat. § 53a-13(a), a defendant may establish that he lacked substantial capacity to appreciate the "wrongfulness" of his conduct if he can prove that, at the time of his criminal act, as a result of mental disease or defect, he substantially misperceived reality and harbored a delusional belief that society, under the circumstances as the defendant honestly but mistakenly understood them, would not have morally condemned his actions.
Defendant committed a homicide, believing that the victim was the mastermind of a large organization bent on controlling the minds of others. Defendant further believed that the victim was responsible for numerous problems that besieged him. At trial, the defendant raised his mental illness as an affirmative defense under § 53a-13. The jury, however, rejected the defendant's claim of insanity and convicted him of murder. The trial court rendered judgment sentencing the defendant to 60 years' imprisonment. Defendant appealed.
Could defendant raise mental illness as an affirmative defense under § 53a-13?
The state supreme court held that defendant had adduced sufficient evidence to warrant a jury instruction on the definition of "wrongfulness" under § 53a-13(a). Basically, the trial court should have instructed the jury that a defendant did not truly "appreciate the wrongfulness of his conduct" if a mental disease or defect caused him both to harbor a distorted perception of reality and to believe that, under the circumstances as he honestly perceived them, his actions did not offend societal morality, even though he may also be aware that society, on the basis of the criminal code, did not condone his actions. Thus, defendant was entitled to prevail under § 53a-13(a) if, as a result of his mental disease or defect, he sincerely believed that society would approve of his conduct if it shared his understanding of the circumstances underlying his actions.
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