State v. Singleton
211 N.J. 157
| N.J. | 2012Background
- Defendant Singleton killed his pregnant girlfriend Michelle Cazan in Sept. 2005; he admitted to the killing.
- Defendant suffered schizoaffective disorder with delusional religious beliefs about God commanding him to kill sinners.
- Trial court instructed with Model Insanity Charge; no objection raised to the instruction at trial.
- Appellate Division reversed for a new trial, finding Worlock deific-command instruction required; remanded.
- State sought certification; Supreme Court granted and reversed, upholding the standard model insanity charge and denying Worlock relief.
- Major issue: whether a deific-command variation to the insanity defense was required or permissible under NJ law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Worlock deific-command instruction should have been given sua sponte | Singleton's belief in a deific command warranted instruction. | Deific-command instruction was required; evidence supported Worlock variation. | No plain error; Worlock not required; standard model charge sufficient. |
| Whether Worlock should be abandoned or broadened | Worlock remains valid; deific-command concept needed for certain delusions. | Worlock should be abandoned or narrowed; its scope is unconstitutional or impractical. | Worlock should not be abandoned; traditional approach retained for now. |
| Standard of reviewing jury instruction errors in insanity defense | Plain error review should apply given lack of objection and potential prejudice. | Standard of review misapplied; remaining issues unresolved. | Plain error standard applied; no reversible error found here. |
| Whether the deific-command concept is compelled by statute or precedent | Legislature did not negate Worlock; deific-command concept remains viable. | Deific-command concept not mandated by statute; should be disfavored. | Concept not mandated; court discouraged its expansion; no statutory basis for broadened instruction. |
| Whether remand should consider other errors raised on appeal | Conviction reversal should be affirmed for other claimed errors. | Remand appropriate to address remaining issues. | Remanded for consideration of remaining claims; not exclusively resolved here. |
Key Cases Cited
- State v. Sikora, 44 N.J. 453 (1965) (mental capacity and moral blameworthiness standard for insanity)
- Worlock, 117 N.J. 596 (1990) (deific-command variation to insanity defense; moral vs legal wrong)
- Winder, 200 N.J. 231 (2009) (restrictive application of deific-command; no expansion absent clear command)
- State v. Walker, 203 N.J. 73 (2010) (when to instruct on statutory defenses sua sponte)
- People v. Schmidt, 216 N.E. 945 (N.Y. 1915) (origins of moral vs legal wrong distinction)