diminished capacity doctrine

In the early hours of June 21, 2000, Officer Jeffrey Moritz of the Flagstaff Police responded in uniform to complaints that a pickup truck with loud music blaring was circling a residential block. When he located the truck, the officer turned on the emergency lights and siren of his marked patrol car. This prompted petitioner Eric Clark, the truck’s driver (then 17), to pull over. Officer Moritz got out of the patrol car and told Clark to stay where he was. Less than a minute later, Clark shot the officer. The officer died soon after but not before calling the police dispatcher for help. Clark ran away on foot but was arrested later that day with gunpowder residue on his hands. The gun that killed the officer was found nearby, stuffed into a knit cap. Clark was charged with first-degree murder under Ariz. Rev. Stat. Ann. §13–1105(A)(3) for intentionally or knowingly killing a law enforcement officer in the line of duty. In March 2001, Clark was found incompetent to stand trial and was committed to a state hospital for treatment. Two years later the same trial court found his competence restored and ordered him to be tried. Clark waived his right to a jury, and the case was heard by the court. At trial, Clark did not contest that he shot the officer or that the officer died. He relied on his own undisputed paranoid schizophrenia at the time of the incident to deny that he had the specific intent to shoot an officer or knowledge that he was doing so. The prosecutor offered circumstantial evidence that Clark knew the victim was a police officer. The prosecutor also offered testimony indicating that Clark had previously stated he wanted to shoot police and had lured the victim to the scene to kill him. In presenting the defense case, Clark claimed mental illness. He sought to introduce it for two purposes. First, he raised the affirmative defense of insanity. This put the burden on himself to prove by clear and convincing evidence that at the time of the crime he was afflicted with a mental disease or defect of such severity that he did not know the criminal act was wrong. Second, he aimed to rebut the prosecution’s evidence of the requisite mens rea. Ruling that Clark could not rely on evidence bearing on insanity to dispute the mens rea, the trial court cited the Arizona Supreme Court’s decision in State v. Mott. That decision refused to allow psychiatric testimony to negate specific intent. It held that Arizona does not allow evidence of a mental disorder short of insanity to negate the mens rea element of a crime. As to his insanity, Clark presented lay testimony describing his increasingly bizarre behavior over the year before the shooting. This included testimony that Clark thought Flagstaff was populated with aliens trying to kill him and that bullets were the only way to stop them. A psychiatrist testified that Clark was suffering from paranoid schizophrenia with delusions about aliens when he killed the officer. The psychiatrist concluded that Clark was incapable of luring the officer or understanding right from wrong and was thus insane at the time of the killing. In rebuttal, the State’s psychiatrist gave his opinion that Clark’s paranoid schizophrenia did not keep him from appreciating the wrongfulness of his conduct before and after the shooting. The judge then issued a first-degree murder verdict. The judge found that Clark had not established that his schizophrenia distorted his perception of reality so severely that he did not know his actions were wrong. Clark moved to vacate the judgment and life sentence. He argued that Arizona’s insanity test and its Mott rule each violate due process. The trial court denied the motion. Affirming, the Arizona Court of Appeals held that the State’s insanity scheme was consistent with due process. The court read Mott as barring the trial court’s consideration of evidence of Clark’s mental illness and capacity directly on the element of mens rea. The Supreme Court of Arizona denied further review. The United States Supreme Court granted certiorari.

On February 21, 1978, Freddie Lee Hall and his accomplice Mark Ruffin kidnapped, beat, raped, and murdered Karol Hurst, a pregnant 21-year-old newlywed. Afterward Hall and Ruffin drove to a convenience store they planned to rob and killed Lonnie Coburn, a sheriff’s deputy who attempted to apprehend them. Hall received the death penalty for both murders, although his sentence for the Coburn murder was later reduced on account of insufficient evidence of premeditation. When Hall was first sentenced, this Court had not yet ruled that the Eighth Amendment prohibits States from imposing the death penalty on persons with intellectual disability. After this Court held that capital defendants must be permitted to present nonstatutory mitigating evidence in death penalty proceedings, Hall was resentenced. Hall then presented substantial and unchallenged evidence of intellectual disability, including school records in which his teachers identified him on numerous occasions as mentally retarded, testimony from his prior lawyer that he could not understand anything Hall said, and testimony from medical clinicians that Hall was significantly retarded and had levels of understanding typically seen with toddlers. Hall’s siblings testified that there was something very wrong with him as a child, that he was slow with speech and slow to learn, and that he walked and talked long after his other brothers and sisters. The sentencing court found substantial evidence that Hall had been mentally retarded his entire life yet still imposed a death sentence, which the Florida Supreme Court affirmed. In 2002, after this Court ruled that the Eighth Amendment prohibited the execution of persons with intellectual disability, Hall filed a motion claiming that he had intellectual disability and could not be executed. More than five years later, Florida held a hearing to consider Hall’s motion. Hall again presented evidence of intellectual disability, including an IQ test score of 71. Hall had received nine IQ evaluations in 40 years, with scores ranging from 60 to 80, but the sentencing court excluded the two scores below 70 for evidentiary reasons, leaving only scores between 71 and 80. In response, Florida argued that Hall could not be found intellectually disabled because Florida law requires that, as a threshold matter, Hall show an IQ test score of 70 or below before presenting any additional evidence of his intellectual disability. The Florida Supreme Court rejected Hall’s appeal and held that Florida’s 70-point threshold was constitutional. This Court granted certiorari.

Brandon Joseph Williams, an Army veteran, was convicted by a jury of murdering Veta Karla Conrad, known as Karla. The jury assessed punishment at sixty-seven years' confinement and a $10,000 fine. Williams timely appealed to the Court of Appeals of Texas, Houston (14th Dist.). Karla and her daughter Sarah were living with Williams at the residence of his mother, Belinda Sue Williams, in Lake Jackson, Texas. Karla and Sarah shared Sue's bedroom while Sue slept on the living room couch and Williams had his own bedroom. On the night of the shooting, Williams, who had been using synthetic marijuana and methamphetamine, woke Sue and said he heard something outside. He told her to take Karla and Sarah into the bathroom, but Sue refused to avoid scaring them. Williams went through the kitchen and out the backdoor. Sue rose and saw him standing in the breezeway by the garage. He appeared startled, fell backwards, then raised and pointed his gun at her while advancing and yelling for her to get on the ground. Sue backed up, turned on a lamp, identified herself as his mother, and knelt on one knee. A single bullet from Williams's gun struck Karla, who had entered the room behind Sue. Sue tackled Williams, causing the gun to fly out of his hand, and held him down until police arrived after Sarah called 911. Approximately twelve hours after the shooting and after emergency medical treatment, Williams gave a recorded statement to investigators. In the statement he described seeing a figure, directing it to put its hands up and identify itself, and firing one round. He acknowledged shooting someone and described delusions and fighting with the devil. Williams tested positive for amphetamines and cannabis; the attending emergency room physician noted his heart rate, blood pressure, and respiratory rate were so elevated from the drugs that an abnormally high level of benzodiazepines was required. At trial Sue testified that she believed Williams had been suffering from PTSD or a flashback, though she had been unaware of his recent drug use in the house.