United States v. Luther S. Cartwright

Summary

The Sixth Circuit held that the limited retroactivity of its newly adopted insanity-defense standard applied to Luther S. Cartwright because his failure to obtain a direct appeal resulted from counsel's failure to follow his instructions. The court reversed his bank-robbery conviction because the jury instruction did not adequately require consideration of whether mental disease deprived him of substantial capacity to conform his conduct to the requirements of law, and remanded for a new trial.

Holdings

1. The limited retroactivity principle announced in United States v. Smith applies where the defendant's appeal is being heard after the district court restored the opportunity for a direct appeal because appointed counsel failed to carry out the defendant's instructions to appeal.
2. The insanity instruction was reversible error because it did not require the jury to determine whether mental disease deprived Cartwright of substantial capacity either to appreciate the criminality or wrongfulness of his conduct or to conform his conduct to the requirements of law.

Questions Presented

1. Whether the limited retroactivity principle announced in United States v. Smith applied to Cartwright's belated direct appeal.
2. Whether the original insanity instruction was reversible error because it failed to require the jury to determine whether mental disease deprived Cartwright of substantial capacity to appreciate the criminality or wrongfulness of his conduct or to conform his conduct to the requirements of law.

Disposition

reversed_and_remanded