State of Minnesota v. Ishmael Roberts, 876 N.W.2d 863

Defendant Ishmael Roberts, diagnosed with schizophrenia/psychosis, stabbed and killed his adoptive relative B.W. and 14-year-old P.W. on October 29, 2012; multiple stab/incision wounds and circumstantial physical evidence tied Roberts to the scene.
Roberts had prior psychiatric hospitalizations (2010) and post-arrest evaluations showing psychotic symptoms; defense expert diagnosed paranoid schizophrenia and opined Roberts was unable to understand moral implications at the time.
State expert concluded substance-induced psychosis in remission and pointed to planning/concealment/flight and post-offense conduct as evidence Roberts knew his acts were wrong.
After a bifurcated bench trial, court found Roberts guilty of two counts of first-degree premeditated murder and, at the mental-illness phase, concluded Roberts failed to prove by a preponderance that he did not know his acts were morally wrong.
The district court relied on circumstantial evidence (use of mask/dark clothing, disposal of bloody shoes and car mat, fleeing across state lines, resisting identification, and statements indicating awareness of consequences) and gave deference to evaluating conflicting expert testimony.

Issue	Plaintiff's Argument (Roberts)	Defendant's Argument (State)	Held
Whether Roberts proved under Minn. Stat. § 611.026 that, at the time of the murders, he did not know his acts were morally wrong	Roberts argued his psychosis and delusions (voices, fears of witchcraft, belief family were attacking his soul) rendered him incapable of appreciating moral wrongfulness	State argued Roberts’s planning, concealment, flight, disposal of evidence, resistance and admissions show awareness of wrongfulness; experts disagreed and State’s expert supported knowing-wrong conclusion	Court held Roberts did not meet his burden; district court did not clearly err in rejecting the mental-illness defense

State v. Linder, 304 N.W.2d 902 (Minn. 1981) (burden of proof for insanity defense is preponderance)
State v. Odell, 676 N.W.2d 646 (Minn. 2004) (deference to fact-finder on psychiatric testimony)
State v. Bott, 246 N.W.2d 48 (Minn. 1976) (statutory “wrong” means moral wrong)
State v. Ulm, 326 N.W.2d 159 (Minn. 1982) (distinguishing legal wrong from moral wrong; requirement of moral-awareness)
State v. DeMars, 352 N.W.2d 13 (Minn. 1984) (circumstantial post-offense conduct can undercut insanity defense)
State v. Rawland, 199 N.W.2d 774 (Minn. 1972) (reversal where all experts agreed defendant was so psychotic he could not know right from wrong)