Melik Ralah Smith v. State, 05-16-00102-CR

Melik Ralah Smith was convicted by a jury of murdering his mother, Onkuli Morris; punishment was 99 years’ imprisonment. Appellant appealed claiming evidentiary and jury-charge errors.
Police found Onkuli’s decomposing body in the apartment she shared with appellant; a bloody wooden rod recovered carried DNA matching the victim and appellant. Appellant was found hiding in a closet and arrested.
Appellant has a documented history of serious mental illness (paranoid schizophrenia, bipolar disorder), prior hospitalizations, and was found incompetent to stand trial and sent to Vernon State Hospital after arrest. Family witnesses testified he sometimes stopped taking medication and exhibited psychotic symptoms.
The trial court admitted some testimony from family but excluded additional lay testimony, a post-arrest interrogation videotape, and expert testimony about appellant’s mental illness after hearing those matters outside the jury’s presence.
Experts who evaluated appellant (at various times after the murder) described schizophrenia and psychosis but could not affirmatively say appellant was insane at the time of the offense or that he lacked the ability to form intent to kill.
Appellant also requested a jury charge on the lesser-included offense of manslaughter (recklessness); the trial court denied the instruction. The court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Exclusion of additional lay testimony about mental illness	Excluded family testimony showed appellant’s mental state and would negate mens rea for murder	Evidence was irrelevant to appellant’s mental state at time of offense and cumulative/confusing	Court: No abuse of discretion; testimony did not prove condition at time of killing and could mislead jury
2. Exclusion of interrogation videotape	Tape would show appellant’s mental state and support lack of culpable mental state	Tape reflected post-arrest condition and was not probative of state of mind at time of offense	Court: Properly excluded as not tied to time of offense and potentially misleading
3. Exclusion of expert testimony about mental illness/comptency	Experts’ opinions on schizophrenia/psychosis were relevant to mens rea and should be admitted	Experts could not say appellant lacked ability to form intent at the time; opinions concerned periods after the offense	Court: No abuse of discretion; experts could not negate required intent and evidence was temporally untied to the killing
4. Denial of manslaughter (lesser-included) instruction	Evidence of mental illness and medication noncompliance supported a rational basis for a recklessness instruction	No evidence showing appellant was merely reckless rather than knowing/intending to kill	Court: No error; record lacked evidence directly germane to manslaughter/recklessness

Jackson v. State, 160 S.W.3d 568 (Tex. Crim. App. 2005) (lay and expert testimony about mental illness may be admissible on state of mind but remains subject to evidentiary rules)
Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008) (history of mental illness can be relevant but evidence that does not negate mens rea may be excluded)
Threadgill v. State, 146 S.W.3d 654 (Tex. Crim. App. 2004) (standard of review for submitting lesser-included offense is abuse of discretion)
Cavazos v. State, 382 S.W.3d 377 (Tex. Crim. App. 2012) (analysis distinguishing differing culpable mental states and when lesser offenses apply)
Rice v. State, 333 S.W.3d 140 (Tex. Crim. App. 2011) (second-step test requires some evidence directly germane to the lesser offense)
Mays v. State, 318 S.W.3d 368 (Tex. Crim. App. 2010) (evidence of post-offense mental state may be insufficient to negate mens rea at time of offense)