Flake v. State

Summary

The Arkansas Supreme Court held that the defendant could rely on both insanity and self-defense under a general plea of not guilty. Because the State introduced the defendant's statements as confessions, the jury should have been permitted to consider those statements in evaluating self-defense and whether they were freely and voluntarily made. The court also held that the jury should have been instructed to disregard the confession if the defendant's mental condition or the effects of drugs prevented him from understanding what he was saying, and it reversed and remanded for a new trial.

Holdings

1. Under a general plea of not guilty, a defendant may rely on any defenses supported by the evidence, including both insanity at the time of the killing and self-defense; the defenses are not legally inconsistent merely because both are asserted.
2. When a confession is admitted into evidence, the jury must be permitted to consider the confession in its entirety, including the portion asserting that the killing was in self-defense, when determining whether the killing was justified.
3. The trial court erred by refusing supported instructions on self-defense and voluntary manslaughter.
4. When a confession is admitted but evidence supports that the defendant was so affected by drugs, disease, or mental condition that he did not understand what he was doing or saying, the jury must be instructed to determine whether the confession was freely and voluntarily made and, if not, to disregard it.

Questions Presented

1. Whether a defendant who pleads not guilty may rely simultaneously on insanity and self-defense when the evidence supports both defenses.
2. Whether the jury should have been permitted to consider the defendant's confession in determining whether the killing was committed in self-defense.
3. Whether the trial court was required to instruct the jury on voluntary manslaughter when the evidence supported that instruction.
4. Whether the jury should have been instructed to disregard the confession if the defendant's mental condition or the drugs he had taken rendered him unable to understand what he was doing or saying.

Disposition

reversed_and_remanded