Lantrip v. State
2011 Tex. App. LEXIS 844
| Tex. App. | 2011Background
- Lantrip, age 73, was convicted of murder and sentenced to life imprisonment after shooting neighbor Gordon on April 10, 2009; he raised an insanity defense, claiming prior head injury and periods of mental illness; the jury rejected insanity and he testified about memory loss and drinking; medical testimony disputed insanity, noting his awareness of wrongfulness; he admitted heavy drinking despite doctors’ warnings about interactions with his brain injury; he sought relief on four grounds including trial attire and admissibility of testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Lantrip’s insanity defense proven by a preponderance of the evidence? | Lantrip asserted severe mental disease or defect at the time of the offense. | State contended evidence failed to show lack of knowledge of wrongfulness; jury could find sanity. | No reversible error; jury reasonably rejected insanity. |
| Did the trial court fail to admonish Lantrip regarding his trial testimony? | Lantrip claimed inadequate admonishments could render testimony involuntary. | State argued no duty to admonish testifying defendant; waiver was voluntary. | No reversible error; admonishments were sufficient. |
| Was Lantrip entitled to a new trial on newly discovered evidence? | Hospital records suggesting altered mental status could impeach expert. | Evidence was not newly discovered, is cumulative or impeaching, and not likely to change result. | Denied; no abuse of discretion. |
| Was Lantrip entitled to wear camouflage clothing at trial? | Lantrip preferred camouflage, arguing it reflected his stance. | Court has discretion to control courtroom decorum; camouflage denied. | Trial court did not abuse discretion; camouflage clothing denied. |
Key Cases Cited
- Manning v. State, 730 S.W.2d 744 (Tex.Crim.App. 1987) (defendant bears burden to prove insanity; sanity presumed)
- Sims v. State, 807 S.W.2d 618 (Tex.App.-Dallas 1991) (insanity defense burden on defendant)
- Meraz v. State, 785 S.W.2d 146 (Tex.Crim.App. 1990) (standard for weighing evidence on insanity defense)
- Dashield v. State, 110 S.W.3d 111 (Tex.App.-Houston [1st Dist.] 2003) (credibility determinations lie with the fact-finder)
- Newell v. State, 461 S.W.2d 403 (Tex.Crim.App. 1970) (no duty to admonish a testifying defendant; waiver presumed voluntary)
- Mullane v. State, 475 S.W.2d 924 (Tex.Crim.App. 1971) (presumption of voluntariness when defendant testifies)
- Estelle v. Williams, 425 U.S. 501 (U.S. 1975) (appearance in jail clothes implicates presumption of innocence)
- Gonzales v. State, 2 S.W.3d 600 (Tex.App.-Texarkana 1999) (trial court has discretion to control courtroom decorum)
- Taylor v. State, 856 S.W.2d 459 (Tex.App.-Houston [1st Dist.] 1993) (distinction between medical and legal insanity)