People in the United States commit crimes and make up excuses why they should not be held accountable for a crime. Insanity and temporary Insanity have significant differences. One might ask themselves is there really any meaningful difference? During the history of our court system there has been many significant court decisions which address the controversy topics of insanity and temporary insanity as it relates to criminal procedures. One of the most significant court decision is Miller Vs State Supreme Court of Nevada, 1996 991 P.2d 1183.
FactsOn May 8, 1993, hearing a commotion, Officer Maria Jordan went to an upstairs neighbors apartment; when John K. Miller opened the door she noticed bloodstains on Millers clothes. Officers responded to the 911 call and observed Millers girlfriend and mother of their two children, Robyn Goring, lying on the kitchen floor with a knife protruding from her torso. On June 10, 1993, Miller was charged with first-degree murder with the use of a deadly weapon (Schmalleger, 2002).
At the trial, Gorings mother and sister testified that Goring was going to leave Miller because he was too controlling and violent towards her. A psychiatry expert, Thomas Bittker, testified that Millers medical history conspicuously lacked any evidence of amnesia or a violent episode associated with a specific seizure and that there was no clear evidence existed to connect his seizure episode with the killing of Goring (Schmalleger, 2002).
Bittker concludes that Miller was sane at the time of the murder. Norton Roitman, a certified psychiatrist, concluded that if it were not for Millers condition the murder of Goring would have never happened and that Miller was not sane at the time of the murder. Austin Moody, a certified neurologist, agrees with Roitman (Schmalleger, 2002). Moody and Dr. Jack Jurasky, a psychiatrist, testifies that before the stabbing, Miller was sane; but during the stabbing, Miller could not appreciate the nature of his actions and was insane.
HistoryOn May 8, 1993, Robyn Goring was stabbed 42 times to death in the apartment she shared with John Kilioi Miller and their two children. Maria Jordan, an officer on the Las Vegas police force, lived directly below Goring and Millers apartment. She heard loud noises in the apartment above her and went up to investigate. Miller opened the door and stated something to the effect that I blew it or I lost it. Miller stated that he did not deserve to be treated nicely. Miller was informed of his Miranda rights and proceeded to volunteer incriminating statements. Miller stated, I lost control and I just picked her up, and Im sorry. I dont want to live anymore. Shoot me (Schmalleger, 2002).
At the trial Millers sister, Annie Pedro, testified that on one occasion, Miller hit their brother ten times in an outburst that ended as abruptly as it began. Afterwards, Miller was very apologetic. Pedro stated that on another occasion, Miller struck her several times and immediately apologized, not knowing why he had hit her. Millers father testified that Miller had no memory of attacking Goring and that there were numerous things his son did not remember (Schmalleger, 2002).
The Issue before the Court in the Appeal of MillerDid the district court properly refused to give instructions to Millers jury regarding the insanity defense? Did the prosecutions and the district courts comments regarding temporary insanity prejudice Miller? The denial of Millers jury instructions, and the subsequent comments of the State and the district court regarding temporary insanity, confused the jury and prejudiced Millers trial.
DecisionThe jury found Miller guilty of first-degree murder with the use of a deadly weapon and was sentenced to life in prison without the possibility of parole (Schmalleger, 2002). The appellate court reversed Millers conviction and remanded the case for a new trial.
RationaleMillers defense was that he was sane before and after killing Goring but was insane during the killing. Three medical experts testified that his mental condition caused him to have violent seizures while completely sane. Additional testimony showed that Miller acted extremely violent without the ability to appreciate the nature of his actions, and Miller became remorseful after a seizure and realized the nature of his conduct.
Miller presented evidence that on May 8, 1993, he fell into a violent seizure, stabbed Goring 42 times, and came out of the seizure consumed with remorse. Three medical experts concluded that Miller satisfied the MNaughten insanity test during the period in which he stabbed Goring. The test for insanity had been used in Nevada since 1889. State v. Lewis, 20 Nev.333, 22 P.241 (1889). The defense used the MNaughten test to show that the defendant did not understand his actions and could not tell the difference between right and wrong. During the close of evidence in the trial the district court instructed the jury to determine if Miller was legally insane when he killed Goring.
The defendant was legally insane and legally sane at different times during the commission of the crime. Miller had the burden of proof by a preponderance of the evidence to show that he was legally insane at the time of the crime. Temporary insanity is not recognized as a defense in the State of Nevada and the district court denied Millers instructions to the jury regarding this defense. Miller presented competent evidence that he was insane when he killed Goring but was sane before and after the killing.
In conclusion, many people often try to get away with their criminal acts by attempting to play into the courts kindness with mental illness. Is there a meaningful difference between insanity and criminal insanity? The Supreme Court has attempted to answer these questions in the significant court case of Miller Vs State Supreme Court of Nevada, 1996 991 P.2d 1183.
Schmalleger, F. (2002). Criminal law today: An introduction with capstone cases (2nd Ed). Upper Saddle River, NJ: Prentice-Hall.
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