United States v. Goodman
633 F.3d 963
10th Cir.2011Background
- Goodman is an Iraq War veteran who, after returning home, robbed three convenience stores at gunpoint over eight days and attempted a fourth before being apprehended.
- He offered insanity as his sole defense at trial, and was convicted of multiple robbery and firearms offenses.
- The district court sentenced him to 82 years in prison.
- Goodman challenged the trial court’s limits on lay witness testimony, including restricting testimony to observations immediately around the crimes and to non-opinion testimony.
- He also challenged the court’s allowance of hypothetical facts to elicit expert PTSD diagnoses.
- The Tenth Circuit reversed and remanded for a new trial, finding error in the lay-witness limitations but not in the hypothetical-questions approach.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Temporal limits on lay testimony | Goodman contends witnesses may discuss pre- and post-crime behavior over a multi-year span. | The government argues the court properly limited testimony to the days immediately surrounding the crimes. | District court erred; broader lay testimony permitted. |
| Lay witness opinions versus non-opinion testimony | Lay witnesses should be allowed to offer opinions about sanity. | Limitations to non-opinion testimony were appropriate under Rule 704(b). | District court erred in restricting lay opinions on mental state. |
| Hypothetical facts to elicit PTSD diagnoses | Prosecutor’s hypotheticals to test PTSD diagnoses were improper under Rule 704(b). | Hypotheticals mirroring the facts are permissible to aid the jury. | District court did not err; use of hypothetical facts allowed. |
Key Cases Cited
- United States v. Austin, 933 F.2d 833 (10th Cir. 1991) (insanity evidence admissible broadly, no fixed temporal limit)
- United States v. LeRoy, 944 F.2d 787 (10th Cir. 1991) (lay opinion admissible if personal knowledge and observation exist)
- United States v. Rea, 958 F.2d 1206 (2d Cir. 1992) (recognizes lay opinion on mental state permitted; Rule 704(b) applies to experts)
- United States v. Hauert, 40 F.3d 197 (7th Cir. 1994) (lay witness may give opinion about mental state under appropriate circumstances)
- United States v. Richard, 969 F.2d 849 (10th Cir. 1992) (Rule 704(b) does not bar lay testimony; limits apply to experts)