Lori Barcroft v. State of Indiana
89 N.E.3d 448
| Ind. Ct. App. | 2017Background
- Lori Barcroft shot and killed Pastor Jaman Iseminger at a church in May 2012; she was arrested shortly after, calmly admitted the shooting, and made extensive statements reflecting a long history of complex delusions.
- Mental-health records and outpatient contacts (2004–2010) showed prior psychiatric symptoms; post-arrest she refused antipsychotics.
- Three expert examiners (defense and court-appointed) unanimously diagnosed psychotic disorder (schizophrenia or delusional disorder) and opined she could not appreciate the wrongfulness of her conduct at the time of the shooting.
- Lay witnesses described planning-like behavior (waiting, directing a bystander to leave), effective hiding after the shooting, and a calm, cooperative demeanor at arrest and during the interview in which Barcroft admitted the killing.
- The trial court (bench trial) found Barcroft guilty but mentally ill, relying solely on demeanor evidence to conclude she appreciated the wrongfulness of her conduct; the appellate court reversed and ordered entry of not guilty by reason of insanity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence supported rejection of insanity defense (i.e., that defendant appreciated wrongfulness at time of offense) | Barcroft: unanimous expert opinion and long history of psychosis show she could not appreciate wrongfulness; demeanor evidence, when considered with experts, is neutral | State: demeanor and conduct (planning, hiding, statements, motive apart from delusion) support inference she appreciated wrongfulness | Reversed: court erred; demeanor evidence, in context of long-standing psychosis and unanimous expert opinions (which already considered demeanor), was not probative and evidence leads only to insanity finding |
Key Cases Cited
- Galloway v. State, 938 N.E.2d 699 (Ind. 2010) (expert testimony advisory; unanimous experts not conclusive; demeanor may be probative but has limited value when long history of psychosis)
- Kelley v. State, 2 N.E.3d 777 (Ind. Ct. App. 2014) (trial court cannot rely on demeanor evidence that experts already considered to defeat insanity defense)
- Moler v. State, 782 N.E.2d 454 (Ind. Ct. App. 2003) (demeanor evidence has limited probative value for schizophrenic defendants)
- Myers v. State, 27 N.E.3d 1069 (Ind. 2015) (appellate courts must give deference to factfinder’s sanity determinations but reversal required when evidence is unconflicted and leads only to insanity)
- Thompson v. State, 804 N.E.2d 1146 (Ind. 2004) (factfinder may consider behavior before/during/after crime; standard of review explained)
- Barany v. State, 658 N.E.2d 60 (Ind. 1995) (behavior around crime can be more probative than later exams)
- Carson v. State, 963 N.E.2d 670 (Ind. Ct. App. 2012) (cases upholding guilty but mentally ill where demeanor/other evidence created conflict with expert opinions)