United States v. Mott
2013 WL 3388504
C.A.A.F.2013Background
- Appellant Mott, a seaman, was convicted by general court-martial of attempted premeditated murder under Article 80, UCMJ.
- The Navy-Marine Corps CCA affirmed; this court granted review on two issues: wrongfulness standard and waiver of rights under the Fifth Amendment/Article 31(b).
- Appellant’s experts stated he suffered from severe paranoid schizophrenia, affecting his understanding of wrongfulness at the time of the offense.
- The military judge instructed the jury with an objective standard for wrongfulness, focusing on societal standards rather than Appellant’s subjective belief.
- There was contested evidence on whether Appellant knowingly and intelligently waived his rights to counsel during NCIS interrogation; the defense presented expert testimony that he could not understand rights due to psychosis.
- The court ultimately held the military judge correctly instructed on wrongfulness but abused his discretion by admitting Appellant’s statement without a proper Edwards v. Arizona framework analysis on knowing and intelligent waiver.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for wrongfulness in Article 50a insanity defense | Mott argues wrongfulness is subjective to the accused’s beliefs | Mott argues an objective standard should apply | Wrongfulness must be objectively determined; court adopts objective standard |
| Knowing and intelligent waiver of rights (Edwards framework) | Mott contends psychosis prevented knowing, intelligent waiver | Government argues waiver shown by preponderance of evidence | Military judge abused discretion by not applying Edwards separately to voluntary and knowing waiver; admission not necessarily barred, but error reversible and not harmless beyond a reasonable doubt |
Key Cases Cited
- United States v. Ewing, 494 F.3d 607 (7th Cir. 2007) (defines wrongfulness as objective societal standards of morality)
- State v. Worlock, 569 A.2d 1314 (N.J. 1990) (societal morality expressed through law; objective wrongfulness standard)
- State v. Cole, 755 A.2d 202 (Conn. 2000) (wrongfulness tied to societal standards, not the defendant’s personal morals)