Brent Troy Bartel v. State
02-16-00020-CR
| Tex. App. | Mar 23, 2017Background
- Brent Troy Bartel was convicted of aggravated assault on a family member with a deadly weapon and injury to a child (concurrent 11- and 10-year sentences) after cutting a pentagram into his six‑year‑old son’s back on 12/12/12.
- Bartel has a long history of severe mental illness (schizophrenia); he believed the cutting was a blood atonement to save his wife and that 12/12/12 was the end of the world.
- He admitted the act and told police he knew it was against “man’s law” but was “operating under God’s law;” he also gave a voluntary five‑page statement explaining his motive.
- Multiple mental‑health evaluators (including Dr. Antoinette McGarrahan and Dr. Randy Price) agreed he suffered severe mental illness; McGarrahan emphasized his belief the act was morally right, Price concluded he knew the conduct was illegal.
- Bartel raised insanity as an affirmative defense (burden to prove by preponderance); jury implicitly rejected it and convicted him.
Issues
| Issue | Bartel’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether evidence was legally insufficient to support jury’s rejection of insanity defense | Bartel argued his severe schizophrenia and expert testimony (McGarrahan) conclusively showed he did not know his conduct was wrong | State pointed to Bartel’s admissions he knew cutting was against man’s law and expert testimony (Price) that he knew conduct was illegal | Rejected — legal sufficiency supported: more than a scintilla showed he knew conduct was proscribed by law |
| Whether evidence was factually insufficient (against the great weight) to reject insanity | Bartel argued the weight of evidence (McGarrahan spent more time with him; belief act was right) made the verdict manifestly unjust | State urged deference to jury credibility determinations and emphasized admissions and contrary expert opinion | Rejected — factual sufficiency upheld; jury could credit Price and admissions over McGarrahan |
| Whether mental illness alone satisfies legal insanity | Bartel treated his schizophrenia as dispositive | State argued severe mental illness does not equal legal insanity; must show defendant did not know conduct was illegal | Court held mental illness alone is insufficient; must show lack of knowledge that conduct was proscribed by law |
| Standard of review for affirmative‑defense sufficiency | Bartel urged reversal based on preponderance showing of insanity | State relied on civil sufficiency standards applied to affirmative defenses and deference to credibility | Court applied Matlock standards: legal review ignores evidence jury could disbelieve; factual review examines whole record neutrally — affirmed convictions |
Key Cases Cited
- Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (insanity requires lack of knowledge that conduct is illegal; moral justification not sufficient)
- Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (standards for civil‑style sufficiency review of adverse findings on affirmative defenses)
- Bigby v. State, 892 S.W.2d 864 (Tex. Crim. App. 1994) (definition of legal insanity under Penal Code)
- Plough v. State, 725 S.W.2d 494 (Tex. App.—Corpus Christi 1987) (insanity is a legal, not purely medical, determination)
- Tanner v. Nationwide Mut. Fire Ins. Co., 289 S.W.3d 828 (Tex. 2009) (standard that affirmative defense must conclusively prove defense to overcome deference)
- Pham v. State, 463 S.W.3d 660 (Tex. App.—Amarillo 2015) (examples of more‑than‑scintilla evidence supporting jury rejection of insanity)
- Fisher v. State, 397 S.W.3d 740 (Tex. App.—Houston [14th Dist.] 2013) (mental illness does not automatically satisfy legal insanity requirement)
- Reyes v. State, 480 S.W.3d 70 (Tex. App.—Fort Worth 2016) (affirming rejection of insanity where evidence showed defendant knew conduct was illegal)
- McAfee v. State, 467 S.W.3d 622 (Tex. App.—Houston [1st Dist.] 2015) (affirming sufficiency where contrary expert and admissions supported jury’s finding)