Law School Case Brief
United States v. Freeman - 804 F.2d 1574 (11th Cir. 1986)
Under the Insanity Defense Reform Act of 1984, 18 U.S.C.S. § 20 (Supp.1986), the definition of insanity is restricted so that a valid defense only exists where the defendant is unable to appreciate the nature and quality or the wrongfulness of his acts at the time of the offense. The amendment eliminated the volitional prong of the defense; prior to the Act, a defendant could assert a valid defense if he were unable to appreciate the nature of his act or unable to conform his conduct to the requirements of law.
Appellant Dwayne Freeman challenged his conviction of bank robbery under 18 U.S.C.S. § 2113(b), (d) (1982). At trial in federal district court, the facts surrounding the robbery and Freeman's guilt were never at issue. On appeal, Freeman merely contested the trial court's determination that he was sane at the time of the offense. Freeman based his appeal upon two grounds. First, he challenged the constitutionality of the Insanity Defense Reform Act of 1984, 18 U.S.C.S. § 20 (Supp.1986). Second, Freeman asserted that as a matter of law, he had established his insanity by clear and convincing evidence.
(1) Was the Insanity Defense Reform Act of 1984 constitutional?; (2) Did Freeman establish his insanity by clear and convincing evidence?
No to both.
The Insanity Defense Reform Act produced three principal changes to the insanity defense in federal courts. First, the definition of insanity was restricted so that a valid defense only exists where the defendant was "unable to appreciate the nature and quality or the wrongfulness of his acts" at the time of the offense. The amendment thus eliminated the volitional prong of the defense. The second change produced by the Act resulted in a shifting of the burden of proof from the government to the defendant: The defendant must prove his insanity by clear and convincing evidence to escape criminal liability. The third change prohibits experts for either the government or defendant from testifying as to the ultimate issue of the accused's sanity.
The definitional change of insanity brought about by the Insanity Reform Act did not violate the Freeman's constitutional rights. Admittedly, under the new statute, a defendant who was unable to conform his actions to the requirements of law may be convicted of a crime. Such a conviction, however, did not constitute cruel and unusual punishment. It is not cruel and unusual punishment for Congress to restrict the defense of insanity to those persons who are capable of proving that they did not understand the nature and quality of the act committed.
Ample evidence existed indicating that Freeman knew his conduct was wrongful. The evidence showed Freeman changed his clothes after robbing the bank to avoid identification. Freeman employed a mask, handgun, and satchel to execute the robbery and avoid apprehension. He informed bank personnel that if the police were called, he would come back and kill everyone. When spotted by police, Freeman ran to avoid apprehension. Finally, Freeman's probation officer observed Freeman's demeanor as being entirely appropriate following his arrest. The district court's decision was not clearly erroneous.
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