State v. Handy
25 A.3d 1140
| N.J. Super. Ct. App. Div. | 2011Background
- Defendant Handy fatally stabbed his uncle Arthur Cooper in Paterson on Jan 13, 2004; no eyewitnesses.
- Handy has long-standing mental illness; multiple hospitalizations and later competency evaluations.
- Pre-trial, the State argued for bifurcated proceedings (insanity first) per Khan, while Handy’s counsel opposed.
- A trial court followed Khan, holding Handy competent to stand trial but incompetent to waive insanity; insanity first was ordered.
- Handy waived a jury for the insanity phase; the bench trial on insanity found him not guilty by reason of insanity, with self-defense not fully adjudicated.
- On appeal, Handy challenges Khan-based bifurcation, contends he was deprived of a plenary self-defense trial, and seeks remand with potential plenary proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Khan's bifurcation rule still valid? | Handy argues Khan is contrary to the Code and should not govern remand. | Handy contends Khan improperly prioritizes insanity and is not aligned with current law. | Khan is overruled; bifurcation relapse rejected. |
| Did the bifurcated approach deprive Handy of a plenary self-defense trial? | State asserts no denial; evidence limited. | Handy asserts denial of self-defense plenary presentation violated rights. | Handy was deprived of full self-defense consideration; remand required with two-phase or sequenced remand trial. |
| What remand remedy cures the due process and double jeopardy concerns? | State contends no need for remand; preserve insanity disposition. | Handy seeks plenary trial on self-defense with potential acquittal. | Remand allowed with choice: keep insanity disposition or waive it for new trial on merits; two-phase remand favored. |
| What is the proper remand structure to preserve fairness? | Unitary remand trial urged to minimize prejudice. | Sequenced two-phase approach better avoids spillover prejudice. | Remand to be two-phased before same jury: first merits including self-defense, then insanity if necessary; defendant may waive sequencing. |
Key Cases Cited
- Khan, 175 N.J. Super. 72 (App.Div. 1980) (bifurcated insanity-first procedure questioned)
- Frendak v. United States, 408 A.2d 364 (D.C. Cir. 1979) (insanity defense decisions; defendant's right to decide)
- Whalem v. United States, 346 F.2d 812 (D.C. Cir. 1965) (insanity defense succession and sua sponte duties caution)
- Marble, 940 F.2d 1543 (D.C. Cir. 1991) (defendant may choose to accept responsibility despite mental illness; overruled Whalem)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (self-representation; defendant's right to control defense strategy)