Allams v. The State

Supreme Court of Georgia1905-07-17

123 Ga. 500

Summary · law.co

Holding. The judgment was affirmed. The trial court did not err in its jury instructions on the insanity defense or in refusing a new trial, as the evidence fully supported the verdict and any initial inaccuracy in the charging language was cured by subsequent clear and correct instruction.

A defendant charged with murder presented an insanity defense, arguing he lacked criminal responsibility due to mental illness at the time of the killing. The trial court instructed the jury that the defendant bore the burden of proving insanity by a preponderance of the evidence to the reasonable satisfaction of the jury. The court also told jurors that if prior insanity was established, a presumption of continued insanity would arise, shifting to the state the burden of proving the defendant was mentally sound at the time of the homicide.

The defendant challenged the jury instructions as erroneous. The appellate court addressed the precise legal standard for insanity in the state. It clarified that criminal responsibility can be negated by mental delusion even when a person can distinguish right from wrong, provided the delusion so overpowers the will that there is no criminal intent and the unlawful act is connected to the delusion. The court found that although one instruction was not a perfectly accurate statement of the law, it was not reversible error because the trial judge subsequently provided a full, clear, and correct instruction on insanity law and properly applied it to the defendant's contentions.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Burden of proof for the insanity defense in a murder prosecution
Legal standard for insanity as a complete defense to criminal responsibility
Effect of prior insanity as evidence of continued insanity at time of alleged crime
Whether inaccurate jury instruction on insanity requires reversal when corrected by subsequent instruction

Procedural posture

The defendant appealed his murder conviction from Coweta Superior Court, challenging the trial court's jury instructions on the insanity defense and its denial of a motion for new trial.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

majority opinion

Fish, P. J.

1. Where the accused, on trial for murder, relied on the defense of insanity at the time of the homicide, it was not error to instruct the jury that the burden was upon him to show “ that at the time of the hilling he was not of sound memory and discretion. He must show this, not beyond a reasonable doubt, but to the reasonable satisfaction of the jury, by a preponderance of the evidence.” Beck v. State, 76 Ga. 452 (7); Keener v. State, 97 Ga. 388 (3); Minder v. State, 113 Ga. 772 (3).

2. Nor was it error, on the trial of such a case, to charge the jury that if the accused had been shown to be insane prior to the date of the homicide, the presumption would be that he continued to be insane, “ and the burden of proof would be upon the State to show to the reasonable satisfaction of the jury, by a preponderance of the evidence, that at the time of the alleged homicide the defendant was of sound memory and discretion.” Danforth v. State, 75 Ga. 614 (4).

3. “The rule of law in force in this State, which relieves one from criminal responsibility for the commission of an unlawful act on account of mental disease, is: If a man has reason sufficient to distinguish between right and wrong in relation to a particular act about to be committed, he is criminally responsible. An exception to this rule is, where a man has reason sufficient to distinguish between right and wrong as to a particular act about to be committed, yet, in consequence of some delusion, his will is overmastered, and there is no criminal intent; provided, that, the act itself is connected with the peculiar delusion under which the prisoner is laboring.” Taylor v. State, 105 Ga. 746 (1). It follows, therefore, that it was not accurate to charge as follows: “ The insanity which the law recognizes as an excuse for crime must be such as dethrones reasonand incapacitates an individual from distinguishing between right and wrong as to the particular act in question, and of being mentally incapable of choosing to do or not to do the alleged act, and governing his conduct in accordance therewith.” To relieve one from criminal responsibility on account of mental delusion for the commission of an unlawful act, it is not necessary that he be incapable of distinguishing right from wrong as to the particular act in question, and -also incapable of choosing to do or not to do such act and of governing his conduct in accordance therewith. The charge referred to in Quattlebaum v. State, 119 Ga. 433 (1), was not approved as a correct statement of the law ; hut it was held merely that the charge there given furnished the accused no cause of complaint, as it placed a greater burden on the State than the law authorizes. The inaccurarcy of the charge last above quoted was not cause for a new trial, however, when the court subsequently fully, clearly, and correctly instructed the jury on the law of insanity as an excuse for crime, and specifically applied the correct rule on the subject to the contentions of the accused.

Submitted June 19,

Decided July 17, 1905.

Indictment for murder. Before Judge Freeman. Coweta superior court. April 10, 1905.

L. M. Farmer, W. 3. Daniel, R. O. Jones, Robert Orr, and J. L. Jones, for plaintiff in error.- John G. Hart, attorney-general, and J. R. Terrell, solicitor-general, contra.

4. The evidence fully warranted the verdict, and the court did not err in refusing a new trial.

Judgment affirmed.

All the Justices concur, except Simmons, G. J., absent.