In the context of civil liability for an intentional tort, unless an actor is a child, his insanity or other mental deficiency does not relieve the actor from liability for conduct which does not conform to the standard of a reasonable man under like circumstances. This majority rule has been applied to cases involving intentional homicide.
Defendant tortfeasor appealed a decision of the Superior Court in the Judicial District of Windham (Connecticut), which rendered judgment for plaintiff executrix in her action against to recover damages for the wrongful death of her husband. The tortfeasor was charged with the decedent's murder pursuant to Conn. Gen. Stat. § 53a-54a(a), but was found not guilty by reason of insanity pursuant to Conn. Gen. Stat. § 53a-13. The tortfeasor claimed that the trial court should have applied a two-pronged analysis by considering whether he intended the act which produced the injury and whether he intended the resulting injury.
Whether a defendant who is held to be of unsound mind can nevertheless be held liable for an intentional tort?
The court found no error. Initially, it followed the majority rule in that insane persons were civilly liable for their torts. On this analysis, the tortfeasor argued that his acts were external manifestations of irrational thoughts, rather than being intended acts. However, precedent has established that an insane person could have an intent to harm another, even though his reasons and motives for forming that intention were irrational.
Additionally, given the tortfeasor's statements on the incident, the trial court found that the tortfeasor committed an "act" that can be a basis for liability. Further, the lower court did not err in failing to find that the tortfeasor intended that the death would result from that act, because intent was not an element for a cause of action in a wrongful death, and the tortfeasor's statements to the police supported a finding of intent to beat and shoot the decedent.