State v. June Gorthy(075009), 145 A.3d 146

Background

Over a decade defendant June Gorthy persistently contacted a New Jersey therapist (C.L.) despite repeated rejections; police found knives, guns, hollow-point bullets, and an axe in her vehicle when she traveled to New Jersey.
Gorthy was indicted on stalking and weapons charges; she entered PTI but later violated conditions and was re-indicted. Defense counsel raised competency concerns and the court ordered psychiatric evaluations.
Mental health experts diagnosed a delusional disorder but opined Gorthy was competent to stand trial; a defense psychiatrist also opined she met the statutory insanity standard for the stalking conduct.
At trial Gorthy refused to assert an insanity defense (fearing "hospital time"/civil commitment); the court conducted a detailed colloquy, concluded she could not knowingly and intelligently waive the insanity defense, and asserted it on her behalf for the stalking count.
Jury found Gorthy not guilty by reason of insanity on stalking, convicted her on weapons counts; she was civilly committed on the stalking disposition and received probation for weapons convictions.
On appeal the Appellate Division panels split; the Supreme Court of New Jersey held that a competent defendant has autonomy to decide whether to assert insanity, reversed the acquittal-by-insanity on stalking, affirmed weapons convictions, and remanded for new competency determination and, if appropriate, retrial on stalking.

Issues

Issue	State's Argument	Gorthy's Argument	Held
May a trial court interpose the insanity defense over a defendant found competent who refuses it?	Court may assert insanity if defendant’s delusion prevents a knowing, intelligent, voluntary waiver; protecting society and just outcomes justifies intervention.	Once declared competent under N.J.S.A. 2C:4-4, defendant has autonomy to refuse insanity; her fear of civil commitment made the refusal rational.	A competent defendant has the right to decide whether to assert insanity after a detailed colloquy; the court erred by invoking the defense over Gorthy’s informed refusal.
What procedure should a court follow when a defendant declines insanity despite evidence supporting it?	(State) Courts should assess knowing and voluntary nature; procedure can include thorough inquiry.	(Gorthy) Court need only assess capacity to waive; detailed inquiry unnecessary beyond competency finding.	Court must conduct a detailed colloquy at close of State’s case explaining nature of the defense, available evidence, sentencing exposure, and civil-commitment consequences, then respect competent defendant’s choice.
Does a competency finding under N.J.S.A. 2C:4-4 necessarily permit the defendant to make strategic trial decisions?	(State) Some mental impairments may affect particular strategic choices even if competency is found.	(Gorthy) Competency implies capacity to make strategic decisions, including refusing insanity.	Competency under N.J.S.A. 2C:4-4 includes capacity to interact with counsel and make defense decisions; a competent defendant’s strategic choices must be respected.
Were the weapons convictions and evidentiary rulings proper despite the insanity ruling error?	Evidence of other weapons was relevant to stalking and admissible; prosecutor’s single remark not prejudicial; jury queries properly answered.	Admission of uncharged weapons and prosecutor’s remark denied a fair trial.	Appellate Division affirmed: evidentiary rulings and prosecutor’s isolated comment did not produce unjust result; weapons convictions affirmed.

Key Cases Cited

State v. Handy, 215 N.J. 334 (N.J. 2013) (unitary trial required for substantive and insanity defenses; court must conduct searching inquiry when competent defendant waives insanity)
State v. Khan, 175 N.J. Super. 72 (App. Div. 1980) (approved sua sponte assertion of insanity where waiver not intelligent; prescribed bifurcated procedure later disapproved)
Frendak v. United States, 408 A.2d 364 (D.C. Ct. App. 1979) (courts may impose insanity defense when defendant cannot intelligently waive it)
Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (competency hearings require fact-sensitive inquiry; no fixed signs mandate further inquiry)