State v. Campbell, 169 Conn. App. 156

Background

Defendant Richard Campbell was tried by the court and convicted of attempted murder and risk of injury to a child for attacking T.C. with a hammer in her home while her six‑year‑old child was present.
After the assault, police found the defendant semi‑clothed with apparent blood on him; officers smelled alcohol and he acknowledged drinking beers; he was evaluated at a hospital and later released to police custody.
Defendant admitted to striking the victim but claimed memory gaps; he raised an affirmative defense under Conn. Gen. Stat. § 53a‑13(a) (insanity/mental disease or defect), asserting a volitional incapacity to control his conduct.
Defense called family witness Hernandez (reported past hallucinations, hospitalizations) and expert psychologist Meisler (opined defendant lacked capacity to control behavior; described defendant as ego‑dystonic and acutely impaired).
State introduced evidence undermining Meisler: inconsistencies between Meisler’s trial testimony and his prior report (which identified alcohol/medication as possible contributors), hospital notes showing coherent behavior during evaluation, and conflicts in the defendant’s reports about hearing voices.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court reasonably rejected the insanity (mental disease or defect) affirmative defense	State argued the court rightly found the defense unproven given conflicting evidence and weakened expert opinion	Campbell argued the court ignored undisputed witness testimony and improperly rejected Meisler’s opinion that he lacked substantial capacity to control his conduct	Court affirmed: rejection reasonably supported by evidence and credibility determinations; defendant failed to meet preponderance burden
Whether the factfinder improperly discounted lay witness testimony (Hernandez, Officer Harkins)	State relied on inconsistencies and potential bias to diminish their probative value	Defendant argued those witnesses corroborated Meisler and were “undisputed” support for insanity defense	Court: factfinder may weigh credibility and resolve conflicts; could discount Hernandez for bias and reconcile Harkins’ observations with other inconsistent statements
Whether Meisler’s expert testimony was sufficiently reliable and consistent	State argued Meisler’s trial opinion conflicted with his March 2014 report and left open alcohol/medication effects, undermining reliability	Defendant argued Meisler’s evaluation and tests supported his conclusion of volitional incapacity	Court: trial judge reasonably found Meisler’s basis and consistency unreliable and permissibly gave it little weight
Whether evidence of planning or organized behavior negates volitional incapacity	State pointed to conduct (obtaining hammer, following victim, statements, mobility, interaction with police) as showing capacity to control conduct	Defendant maintained his acute impaired state negated substantial capacity to conform conduct to law	Court: such behavior is relevant; here it supported finding defendant retained sufficient volitional capacity

Key Cases Cited

State v. Medina, 228 Conn. 281 (discusses appellate review and factfinder’s role on insanity evidence)
State v. Revels, 313 Conn. 762 (allocation of burdens when affirmative defense of mental disease or defect is raised)
State v. Quinet, 253 Conn. 392 (factfinder’s authority to weigh and disbelieve insanity evidence and importance of planning evidence)
United Technologies Corp. v. East Windsor, 262 Conn. 11 (trial judge as sole arbiter of witness credibility)
State v. Calabrese, 279 Conn. 393 (factfinder may draw reasonable inferences regarding witness bias)