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As the court construes the Insanity Defense Reform Act, 18 U.S.C.S. § 17, Congress did not intend to bar all evidence of mental abnormality from the jury's consideration of mens rea, but it did require the exclusion of evidence that does not support a legally acceptable theory of a lack of mens rea.
Stephen Pohlot was convicted of five counts of using interstate commerce facilities in the commission of a crime of violence and one count of conspiracy to use interstate commerce facilities in the commission of a crime of violence. After the verdict, Pohlot filed a motion for a judgment of acquittal or a new trial, which the trial court denied. Pohlot sought review, claiming that the trial court improperly refused to instruct the jury on Pohlot’s insanity defense.
Did the trial court err in refusing to instruct the jury on Pohlot’s insanity defense?
The court affirmed, holding that Pohlot had the burden of proving the defense under 18 U.S.C.S. § 17. The psychological evidence was relevant to the issue of establishing whether Pohlot had the appropriate mens rea. After examining the psychological evidence, the record showed that Pohlot was aware of his actions at all times, and was therefore, criminally liable for those actions.