Carlos Whitcomb v. State
03-18-00248-CR
| Tex. App. | Jul 31, 2018Background
- Carlos Whitcomb was tried and convicted by a jury for the murders of his mother and stepfather; punishment assessed at 25 years’ confinement for each murder.
- On May 24, 2013, Whitcomb was found near a creek disoriented and later admitted to hospital; his parents were found shot to death in their home.
- Whitcomb was diagnosed with a subacute subdural hematoma and later underwent neurosurgery; cause and effects of the hematoma were disputed.
- Defense experts opined the hematoma (allegedly from a prior fall) produced Capgras-like delusions and psychosis causing legal insanity; the defense argued Whitcomb did not know his conduct was wrong.
- State experts attributed the hematoma and symptoms to severe alcohol dependence, and the neurosurgeon testified the hematoma predated the alleged fall; they concluded Whitcomb was legally sane.
- The jury rejected the insanity defense; the court affirmed convictions but corrected clerical error in the written judgments to cite Tex. Penal Code § 19.02(b)(1),(c).
Issues
| Issue | Appellant's Argument | State's Argument | Held |
|---|---|---|---|
| Whether the jury’s rejection of insanity was factually insufficient | Whitcomb: medical evidence (hematoma → Capgras/psychosis) shows he was insane and did not know killing was wrong | State: alternative, non-mental-illness explanations (alcohol dependence; hematoma older than fall) rebut insanity | The court held the evidence was factually sufficient to support the jury’s rejection of insanity |
| Causation of hematoma (Costco fall vs. earlier injury) | Whitcomb: hematoma caused by Costco fall shortly before murders | State: neurosurgeon dated hematoma earlier; alcohol dependence explains hematoma | Court credited the jury’s resolution of conflicting medical evidence in favor of State experts |
| Whether delusions (Capgras) negated knowledge of wrongfulness | Whitcomb: Capgras delusions meant he misidentified parents and lacked knowledge that killing was wrong | State: experts said no reliable proof Capgras caused lack of understanding; post-offense conduct showed awareness | Court deferred to jury credibility determinations and the mix of post-offense and medical evidence supporting sanity finding |
| Clerical error in written judgments | Whitcomb: (no substantive challenge) | State/Court: judgments listed only §19.02(c); indictment charged §19.02(b)(1) and (c) applies to penalty | Court modified judgments to list the correct statutes §19.02(b)(1),(c) and affirmed as modified |
Key Cases Cited
- Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (insanity defense standard and burden)
- Matlock v. State, 392 S.W.3d 662 (Tex. Crim. App. 2013) (standard for factual-sufficiency review of rejected affirmative defenses)
- Bigby v. State, 892 S.W.2d 864 (Tex. Crim. App. 1994) (role of jury in resolving insanity and non-medical components)
- Graham v. State, 566 S.W.2d 941 (Tex. Crim. App. 1978) (insanity issue is for the trier of fact)