Summary
The Connecticut Supreme Court affirmed the defendant’s convictions for murder, criminal possession of a pistol or revolver, and carrying a pistol without a permit. The court held that the trial court reasonably rejected the defendant’s affirmative defense of mental disease or defect and was not required to accept the opinions of his defense experts. The court concluded that the record supported findings that the defendant’s conduct was motivated by frustration and anger, that he had exaggerated or fabricated symptoms, and that his psychosis did not substantially impair his ability to conform his conduct to the law.
Topics
Practice areas
Questions Presented
- Whether a trial court may reject unrebutted defense expert testimony concerning an insanity defense when the state presents no rebuttal expert.
- Whether the trial court had a reasonable evidentiary basis to reject the defendant's claim that psychosis substantially impaired his ability to conform his conduct to the requirements of the law.
- Whether the trial court reasonably concluded that the defendant failed to prove the volitional prong of Connecticut's statutory mental-disease-or-defect defense by a preponderance of the evidence.
Holdings
- A fact finder is not required to accept defense expert testimony on insanity merely because the state presents no rebuttal expert, but it may not arbitrarily disregard or reject that testimony. The record must contain an objectively reasonable basis supporting the rejection.
- The defendant failed to prove by a preponderance of the evidence that, as a result of mental disease or defect, he lacked substantial capacity to control his conduct within the requirements of the law.
- The mere fact that a defendant suffers from psychosis and violates the law does not establish that the psychosis substantially impaired the defendant's ability to conform conduct to the requirements of the law.
Key quotations
“The trier’s freedom to discount or reject expert testimony does not, however, allow it to ‘‘arbitrarily disregard, disbelieve or reject an expert’s testimony in the first instance.’’” (State v. Weathers, SC 20297, part II)
“The mere fact that the defendant violated the law does not establish the requisite connection, and, for the foregoing reasons, the trial court was not bound to accept the opinions of the defendant’s experts insofar as they purported to make that connection.” (State v. Weathers, SC 20297, part II)
Factual background
The defendant approached a construction-site worker in Bridgeport to ask whether the construction company was hiring. After being directed to the company's office to complete an application, he walked away, repositioned himself near the truck, returned, and shot the victim several times, killing him. After the shooting, he fled, was apprehended with the revolver, complied with police commands, and made statements concerning employment and a labor dispute. At trial, two defense experts acknowledged that the defendant suffered from some form of psychosis but opined that it substantially impaired his ability to conform his conduct to the law; the trial court found that the defendant failed to establish the necessary causal connection and likely had exaggerated or fabricated symptoms.
Procedural history
The defendant was charged in the Superior Court for the judicial district of Fairfield with murder, criminal possession of a firearm, stealing a firearm, and carrying a pistol or revolver without a permit. A three-judge panel found him guilty of three charges after the state entered a nolle prosequi on the firearm-stealing charge, rejected his insanity defense, and imposed a total effective sentence of forty-five years. The Appellate Court affirmed the judgment, and the Supreme Court granted certification and affirmed the Appellate Court.