State v. Handy
215 N.J. 334
| N.J. | 2013Background
- In 2004 Robert Handy stabbed and killed his uncle Arthur Cooper; Handy claimed self-defense in multiple statements to police. Forensics showed a single stab to the heart.
- Handy had a lengthy history of psychiatric treatment and delusions (paranoid schizophrenia); he stopped medication before the killing and was later forcibly medicated at a forensic hospital where his condition improved.
- Competency evaluations conflicted: a state evaluator (Dr. Chung) found Handy competent to stand trial (if medicated); defense expert (Dr. Harris) found persistent delusions making competency doubtful.
- Trial court found Handy competent to stand trial but not competent to waive an insanity defense; relying on State v. Khan, it ordered a bifurcated trial and tried insanity first; the court found Handy not guilty by reason of insanity and committed him for treatment without ever trying his self-defense claim.
- The Appellate Division rejected Khan’s sequencing (though not all bifurcation), held Handy was deprived of constitutional rights by being forced to try insanity first, and fashioned a remedy allowing retrial with self-defense tried first (conditioned on waiver of double jeopardy), producing the current appeal.
Issues
| Issue | Plaintiff's Argument (Handy) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1. Proper structure for trials when both a substantive defense (e.g., self-defense) and insanity are raised | Khan’s bifurcated, sequential procedure is unconstitutional; defendant should be allowed to try self-defense first or have bifurcation requiring substantive trial before insanity | Abandon Khan; trials should be unitary so juries see all relevant mental-state evidence together | Overruled Khan; courts must use a unitary trial in future where substantive defenses and insanity are tried together |
| 2. Whether a defendant competent to stand trial may nonetheless lack capacity to waive an insanity defense | Once competent to stand trial, the defendant should be allowed to refuse insanity defense and choose substantive defense | Competency to waive an insanity defense may require a searching inquiry; courts should ensure waivers are knowing, voluntary, intelligent | Trial courts must conduct a focused inquiry (similar to waivers of other significant rights) to ensure any decision to waive insanity is knowing and voluntary; competency distinctions may exist but require careful review |
| 3. Whether the denial of a plenary trial on self-defense violated Handy’s constitutional rights and what remedy is appropriate | Deprivation of the right to try self-defense first requires vacatur of the insanity adjudication and release (double jeopardy bars retrial) | Remand for continuation of the original bifurcated trial (second phase) so self-defense can be tried; no double jeopardy problem because trial was never completed | Remanded for limited remedy: re-evaluate competency; if competent, afford Handy the second phase (trial on substantive offense/self-defense) without forcing him to forfeit the insanity verdict; if incompetent, insanity verdict stands |
| 4. Double jeopardy implications of retrying Handy after an insanity acquittal | Re-trying Handy (or vacating the insanity finding then retrying) violates double jeopardy; conviction must be vacated and defendant released | No double jeopardy bar to completing the originally intended bifurcated proceeding; State will not seek to strip Handy of the insanity verdict on remand | No double jeopardy bar to continuing the originally intended second phase; because original bifurcated procedure (as applied) left trial incomplete, remand to continue the trial is permissible; defendant need not choose remedies now |
Key Cases Cited
- State v. Khan, 175 N.J. Super. 72 (App. Div. 1980) (original precedent endorsing bifurcated, sequenced trials for insanity and other defenses)
- State v. Handy, 421 N.J. Super. 559 (App. Div. 2011) (Appellate Division decision departing from Khan and ordering remedial retrial sequencing)
- State v. Krol, 68 N.J. 236 (N.J. 1975) (periodic review and commitment procedures following insanity acquittal)
- In re Winship, 397 U.S. 358 (U.S. 1970) (State must prove elements of offense beyond a reasonable doubt)
- Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (competence to stand trial may differ from competence to conduct one’s own defense)
- State v. Chenique-Puey, 145 N.J. 334 (N.J. 1996) (bifurcation required where evidence admissible in one trial would be inadmissible in another)
- State v. Ragland, 105 N.J. 189 (N.J. 1986) (permitting bifurcated trial to avoid prejudice where evidence of status would unfairly affect jury)