In re People v. Rosas

Summary

The Colorado Supreme Court held that evidence that a mental disease or defect prevented a defendant from forming the culpable mental state required for a charged offense is relevant to insanity. A defendant, including one charged with specific-intent crimes, may not introduce such evidence without first entering a plea of not guilty by reason of insanity. The court made the rule to show cause absolute and remanded for the district court to allow the defendant to enter an insanity plea and, if entered, order a sanity examination.

Holdings

1. Evidence that a mental disease or defect prevented a defendant from forming the culpable mental state required by an offense charged is evidence relevant to the issue of insanity.
2. A defendant, including one charged with specific-intent crimes, may not introduce evidence relevant to the issue of insanity unless the defendant first enters a plea of not guilty by reason of insanity.

Questions Presented

1. Whether evidence that a mental disease or defect prevented a defendant from forming the culpable mental state required by a charged offense is evidence relevant to the issue of insanity.
2. Whether a defendant charged with specific-intent crimes may introduce such evidence without first entering a plea of not guilty by reason of insanity.
3. Whether the district court's ruling permitting the evidence without an NGRI plea warranted extraordinary relief under C.A.R. 21.

Disposition

writ_granted