230 Cal. App. 4th 771
Cal. Ct. App.2014Background
- In April 2010 Anthony Blakely followed Samuel Lamar from a grocery store into the parking lot, struck Lamar repeatedly with a metal object, demanded and took Lamar's money, and fled.
- Blakely was convicted by a jury of assault with a deadly weapon and robbery; the same jury then heard a bifurcated sanity phase after guilt was established.
- At the sanity hearing Blakely testified he had a longstanding diagnosis of schizophrenia, heard voices that identified Lamar as a "demon," and had used PCP-laced marijuana and methamphetamine that day; he also claimed memory gaps and a prior head injury.
- Defense expert Dr. Leeb diagnosed paranoid schizophrenia/schizoaffective disorder but could not opine on Blakely's sanity at the time of the crime due to lack of information; defense argued the delusion could show incapacity to distinguish right from wrong.
- Prosecution expert Dr. Michael testified Blakely was legally sane, noting controlled, goal-directed behavior before and after the attack and signs that Blakely may have exaggerated symptoms; prosecution moved for a directed verdict of sanity.
- The trial court granted the directed verdict, finding no substantial evidence Blakely was incapable of knowing the nature/quality of his acts or distinguishing right from wrong; the court sentenced Blakely to 35 years to life.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by granting a directed verdict of sanity | People: evidence insufficient; defendant failed to show by a preponderance that he was incapable of knowing nature/quality of acts or distinguishing right from wrong | Blakely: schizophrenia, auditory hallucinations (demon delusion), substance use, and expert diagnosis support jury finding he was incapable of distinguishing right from wrong | Court: Affirmed directed verdict — no substantial evidence that Blakely believed his conduct was morally justified or was incapable of distinguishing right from wrong |
Key Cases Cited
- People v. Severance, 138 Cal.App.4th 305 (court may direct verdict of sanity when defendant fails to proffer substantial evidence of legal insanity)
- People v. Lawley, 27 Cal.4th 102 (Paraphrases M'Naghten standard as codified in Prop. 8/§25(b) and recognizes two independent bases for insanity)
- People v. Skinner, 39 Cal.3d 765 (delusional belief that act is morally sanctioned can satisfy incapacity to distinguish right from wrong)
- People v. Ceja, 106 Cal.App.4th 1071 (court may remove sanity issue from jury when evidence is insufficient to support insanity plea)
- People v. Hernandez, 22 Cal.4th 512 (insanity plea concerns punishment rather than guilt; defense bears burden)
- In re Estate of Lances, 216 Cal. 397 (directed verdict standard and view of evidence on demurrer/directed verdict)