Choisnet v. State
295 Ga. 568
| Ga. | 2014Background
- Choisnet stabbed his elderly father to death with multiple implements in their home, resulting in over 200 injuries and death from stabbing and strangulation.
- Defendant has a long history of mental illness with prior hospitalizations and treatments, and recently exhibited severe psychiatric symptoms leading up to the crime.
- Defendant pled not guilty by reason of insanity; the jury found him guilty but mentally ill.
- Trial evidence included expert testimony both supporting a possible psychotic break and disputing involuntariness or delusional control.
- The trial court instructed the jury on insanity defenses (including delusional compulsion) and declined to offer a GBMI verdict option; defendant preserved several objections, which the Court reviews for plain error.
- The court affirmed the conviction and denied the new-trial motion on remand, applying the thirteenth-juror standard for the new-trial review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence supports the verdicts and the insanity defense evidence was properly considered | Choisnet | Choisnet | Supported by substantial evidence |
| Whether the delusional compulsion instruction omitted justification and was plain error | Choisnet sought justification explanation | State did not object; error non-noticed | No plain error; unlikely to affect outcome |
| Whether the trial court erred by not removing GBMI option from jury | GBMI should be removed | Statute requires four verdict options | Not error; GBMI option required by statute |
| Whether pattern instruction on reasonable-doubt after admission was improper | Pattern instruction harmed the defense | Instruction favorable to defense; no harm | No error or harm noted |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for evidence)
- Alvelo v. State, 290 Ga. 609 (Ga. 2012) (delusional compulsion requires justification concept)
- Woods v. State, 291 Ga. 804 (Ga. 2012) (requirement to instruct on justification in delusional-compulsion insanity)
- Durrence v. State, 287 Ga. 213 (Ga. 2010) (precedes Woods on insanity instruction)
- Henderson v. United States, 133 S. Ct. 1121 (U.S. 2013) (plain-error standard for nontraditional errors)