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Norred v. State
297 Ga. 234
Ga.
2015
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Background

  • On April 20, 2010, Richard P. Norred entered his parents’ home, fatally shot his sister Leigh Pope, shot and injured his mother and sister Amy, threatened an infant, then locked doors and shot himself; he survived and was later found in an upstairs bathroom.
  • Norred was indicted on multiple counts including malice murder, attempted murder, aggravated assault, firearm possession, and cruelty to children; a jury convicted him "guilty but mentally ill."
  • At trial Norred asserted an insanity defense and presented expert testimony diagnosing major depressive disorder, Asperger’s disorder, and schizoid personality disorder and opining diminished capacity and delusional beliefs.
  • The State’s court-appointed expert agreed on diagnoses but testified Norred knew right from wrong and was not under a delusional compulsion that overmastered his will.
  • The jury rejected Norred’s insanity defense; the Supreme Court of Georgia reviewed sufficiency of the evidence to support the guilty-but-mentally-ill verdict.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence to support "guilty but mentally ill" verdict Norred: evidence only supports not guilty by reason of insanity because he lacked capacity to distinguish right from wrong or acted under delusional compulsion State: evidence shows Norred knew right from wrong and was not subject to delusional compulsion; jury could reject insanity evidence Affirmed — a rational trier of fact could find Norred failed to prove insanity by preponderance and State proved guilty but mentally ill beyond a reasonable doubt

Key Cases Cited

  • Durrence v. State, 287 Ga. 213 (discusses Georgia insanity standard and burden)
  • Choisnet v. State, 295 Ga. 568 (jury may reject expert insanity evidence)
  • Hudson v. State, 273 Ga. 124 (standards for reviewing insanity findings and jury verdicts)
  • Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
  • Foster v. State, 283 Ga. 47 (application of Jackson sufficiency standard in Georgia)
  • Avelo v. State, 290 Ga. 609 (delusional belief must, if true, justify actions to establish insanity defense)
Read the full case

Case Details

Case Name: Norred v. State
Court Name: Supreme Court of Georgia
Date Published: Jun 1, 2015
Citation: 297 Ga. 234
Docket Number: S15A0405
Court Abbreviation: Ga.