Carson v. State
2012 Ind. App. LEXIS 112
| Ind. Ct. App. | 2012Background
- Carson entered Zuniga's trailer without permission, later cut her hand with a knife, and a fight with Hernandez ensued where a knife was involved.
- He was chased by police, dropped the knife when threatened, and was eventually apprehended; he provided a recorded interview with bizarre references but denied insanity.
- Charges included two counts of attempted murder, two counts of battery by means of a deadly weapon, burglary, and resisting law enforcement; a notice of insanity defense was filed.
- Initially incompetent to stand trial and diagnosed with paranoid schizophrenia; competency restored later, leading to a bench trial.
- Two psychiatric experts diagnosed a severely abnormal mental condition preventing appreciation of wrongfulness at the time of the offenses; the court held GBMI rather than NRI, and later convicted on remaining counts.
- On appeal, Carson challenges the GBMI verdict and contends insufficiency of the burglary conviction; the court affirms both.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GBMI was proper | Carson asserts no conflict; evidence shows inability to appreciate wrongfulness. | GBMI should be reversed to NRI given uncontroverted insanity. | GBMI affirmed; evidence supported ability to appreciate wrongfulness. |
| Sufficiency of burglary conviction | Intent to commit a felony (murder) shown by entry and statements. | Delusions negate mens rea for murder. | Burglary evidence sufficient; intent to commit felony established. |
| Demeanor evidence supporting sanity inference | Demeanor during/after crime supports ability to appreciate wrongfulness. | Demeanor conflicts with expert insanity opinions and should yield to experts. | Evidence supports reasonable inference Carson appreciated wrongfulness; GBMI affirmed. |
| Standard of review for insanity findings | Appellate court defers to trial court's credibility determinations on demeanor. | Appellate review should overturn when no conflict and evidence points to insanity. | Affirmed due to deference to trial court on demeanor and weight of conflict in evidence. |
Key Cases Cited
- Galloway v. State, 938 N.E.2d 699 (Ind. 2010) (insanity defense burden; deference to trier of fact; demeanor evidence varies)
- Barany v. State, 658 N.E.2d 60 (Ind. 1995) (demeanor evidence can support sanity or insanity determinations)
- Moler v. State, 782 N.E.2d 454 (Ind. Ct. App. 2003) (demeanor evidence weighed with expert testimony in GBMI review)
- Thompson v. State, 804 N.E.2d 1146 (Ind. 2004) (demeanor evidence and expert testimony; not sole determinant)
- Anez v. State, 408 N.E.2d 1315 (Ind. Ct. App. 1980) (mistake of fact defense and mens rea considerations in burglary)
- Barr v. Sumner, 183 Ind. 402, 107 N.E.675 (Ind. 1915) (longevity of mental illness history; demeanor evidence not conclusive)