Farrell v. People
2011 V.I. Supreme LEXIS 5
Supreme Court of The Virgin Is...2011Background
- Farrell was charged with contempt constituting domestic violence and disturbing the peace, with a bench trial granted on September 11, 2009.
- A January 25, 2010 order required a mental health evaluation to assess competency, mental state at the offense, causation by mental illness, and current danger.
- Dr. Lu examined Farrell and opined he was competent to stand trial but that the offense was committed due to schizophrenia and related disorders; the offense occurred because of those disorders.
- At the March 22, 2010 bench trial, the court took judicial notice of Dr. Lu’s report and, after closing arguments, found Farrell not guilty by reason of insanity (NGI).
- The court ordered commitment to a forensic facility for treatment, with placement arranged within ninety days, and Farrell appealed April 15, 2010.
- The Virgin Islands Court held that the Superior Court erred in sua sponte imposing NGI and vacated the NGI verdict, directing remand for a new judgment based on admissible evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 3637(a) limit insanity to jury trials? | Farrell contends § 3637(a) confines insanity to jury trials. | People argue § 3637(a) applies to both bench and jury trials, clarifying verdicts for commitment. | Insanity defense available in bench trials; § 3637(a) not so limited. |
| Was the NGI ruling impermissibly imposed sua sponte? | Farrell argues the court cannot impose NGI without his explicit waiver. | People contend the court could raise NGI under Frendak’s framework when appropriate. | Plain error to impose NGI sua sponte without proper Frendak inquiry. |
| Was the admission of Dr. Lu's report via judicial notice proper? | Confrontation concerns and improper reliance on the report were raised. | The court relied on Lu’s report to address sanity. | Improper to admit contents via judicial notice; contributes to error requiring remand. |
| What is the proper remedy for the court's error? | Remand for a new NGI or guilty verdict after excluding improper evidence. | Remand should allow a full Frendak-inquiry style weighing with admissible evidence. | Vacate NGI verdict and remand for new judgment based on admissible evidence; no new trial. |
Key Cases Cited
- Frendak v. United States, 408 A.2d 364 (D.C. 1979) (majority rule requires voluntary and intelligent waiver of insanity defense)
- Nibbs v. People, 52 V.I. 276 (V.I. 2009) (insanity defense requires proof beyond reasonable doubt; defense grounded in statute)
- Harrison v. People, 851 N.E.2d 157 (Ind. 2000s) (not guilty by reason of insanity verdict equates to acquittal in some jurisdictions)
- State v. Baxley, 102 Haw. 130, 73 P.3d 668 (Haw. 2003) (insanity waiver and trial procedures across jurisdictions)