State of Tennessee v. Michael Halliburton, W2015-02157-CCA-R3-CD

Background

Defendant Michael Halliburton brutally attacked his wife with a metal knife sharpener on Sept. 6, 2012; victim sustained severe head wounds, a partially severed finger, and other injuries; daughter intervened and neighbors stopped the attack.
Defendant was convicted by a Shelby County jury of attempted first-degree premeditated murder, two counts of aggravated assault, and one count of domestic assault; successor trial court approved the verdict, merged lesser convictions, and imposed 21 years.
Defense theory: insanity (affirmative defense under Tenn. Code Ann. § 39-11-501) and diminished capacity/ inability to form requisite mens rea due to Brief Psychotic Disorder (defense expert Dr. Ciocca); defendant testified to hallucinations and dissociation during the attack.
State rebuttal: forensic psychologist Dr. Lynne Zager and multiple lay witnesses testified the defendant was oriented, made deliberate statements (e.g., threatened to kill), spared his daughter, cleaned up and arranged affairs after the attack; 9-1-1 call and post-attack conduct used to show capacity and premeditation.
Trial rulings challenged on appeal: (1) sufficiency as to insanity and diminished capacity, (2) admission of bloody/crime-scene photographs and daughter’s bloody clothes, (3) grant of State’s motion in limine and exclusion of two defense witnesses re: victim’s family, and (4) denial of mistrial for alleged sequestration violation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insanity / sufficiency to convict	State: evidence (expert and lay testimony, 9‑1‑1 call, victim statements, acts during/after) supports rejection of insanity and proves elements beyond reasonable doubt	Halliburton: Dr. Ciocca and his testimony proved Brief Psychotic Disorder; he was unable to appreciate nature/wrongfulness or form requisite intent	Court affirmed: jury reasonably discredited insanity and accredited State evidence; insanity not proven by clear and convincing evidence; sufficiency satisfied for attempted premeditated murder and other convictions
Diminished capacity (mens rea)	State: evidence of statements of intent, use of deadly weapon, multiple blows, selective non-injury of daughter, and calm post-act conduct supports capacity/premeditation	Halliburton: expert testimony showing psychotic episode negated ability to form premeditated intent	Court affirmed: jury weighed experts; State presented substantial proof negating incapacity to form requisite mental states
Admission of evidence (photographs, bloody clothing, scene photo, victim’s pre-attack fear)	State: photographs and clothing probative of brutality, premeditation, and corroborate testimony; scene photo relevant despite timing; victim’s fear shows state of mind and lack of provocation	Halliburton: exhibits were cumulative, inflammatory, and prejudicial; scene photo inaccurate; victim’s fear irrelevant to guilt	Court affirmed: trial court limited cumulative photos, found probative value outweighed prejudice; daughter’s clothing admissible to corroborate intervention; scene photo weight, not inadmissibility; victim’s pre-attack fear admissible as state-of-mind evidence
Exclusion of evidence & motion in limine (victim’s family allegations; witnesses Pembroke and Cooley)	Defense: testimony about victim’s family (alleged pedophilia, mistreatment) was critical to show stressors triggering psychosis; exclusion violated confrontation and right to present a defense	State: family allegations irrelevant, prejudicial, and not sufficiently reliable; trial court offered alternative (prove relevance via expert)	Court affirmed: trial court reasonably limited immaterial/unreliable family-attack evidence; defense had opportunity to present context via defendant and expert; exclusion did not violate right to present a defense
Mistrial for alleged jury sequestration breach	Defense: jury left in courtroom during recess with exhibits and personnel present — risk of outside influence required mistrial	State: court officers remained; no evidence jurors were unsupervised or exposed to outside influence	Court affirmed denial: defendant failed to show actual separation or prejudice; possibility alone insufficient to require new trial

Key Cases Cited

State v. Flake, 88 S.W.3d 540 (Tenn. 2002) (standard for appellate review of jury rejection of insanity defense)
State v. Holder, 15 S.W.3d 905 (Tenn. 2000) (insanity is an affirmative defense; burden on defendant)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency-of-the-evidence standard—any rational trier of fact)
State v. Ferrell, 277 S.W.3d 372 (Tenn. 2009) (admissibility of expert testimony to negate intent/diminished-capacity principles)
State v. Hall, 958 S.W.2d 679 (Tenn. 1997) (diminished capacity evidence admissible to negate mens rea; substantive guidance on expert proof)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (factors supporting premeditation)
State v. Bondurant, 4 S.W.3d 662 (Tenn. 1999) (rule of sequestration and burden after showing jury separation)
State v. Brown, 29 S.W.3d 427 (Tenn. 2000) (factors for considering whether exclusion of defense evidence violated right to present a defense)