The Supreme Judicial Court of Maine Ruled that the Trial Court Correctly Analyzed Whether Evidence of Defendant's Mental Abnormality Negated His Requisite Culpable State of Mind
State v. Graham, 113 A.3d 1102 (Me. 2015), reviewed the decision of a trial court case in Maine in which James Graham was convicted of attempted kidnapping and assault. At trial, Mr. Graham presented evidence suggesting that he had a mental abnormality at the time of the offense that caused him to lack the requisite intent that was a key element of the crime of attempted kidnapping. Mr. Graham contended that the trial court erred in analyzing his mental-abnormality defense.
Facts of the Case
On May 22, 2013, a woman drove her two-year-old grandson to meet up with her daughter, the child's mother, at a commuter parking lot in Maine. The grandmother and child arrived at the location first. The mother arrived at the lot and parked next to the grandmother. The mother was followed closely by a sport utility vehicle (SUV) that parked nearby. The driver of the SUV, James Graham, got out of the car and approached the grandmother's car. The grandmother was holding her two-year-old grandson when Mr. Graham grabbed the child's forearm and said angrily, “I'm taking him home with me tonight.” The grandmother responded, “No, you're not,” and Mr. Graham repeated himself. Maintaining his grip on the child, Mr. Graham said, “You don't understand. You have no choice. He's mine now. There's nothing you can do about it.” Mr. Graham pulled forcefully on the child's forearm, but the grandmother maintained her hold on the child and ran away.
Mr. Graham yelled after the grandmother that she needed to repent and pray for forgiveness. The women told Mr. Graham that law enforcement officers were on their way. Mr. Graham responded, “You're going to wish you didn't do that,” then got into his vehicle and drove away. Shortly thereafter, the mother and grandmother drove their cars on the interstate and Mr. Graham followed them in his car. His car was identified by Maine state troopers and he was pulled over and arrested. When the troopers arrested Mr. Graham, he was calm and complied with the troopers' orders. After obtaining a warrant, one of the troopers searched Mr. Graham's car and found a loaded semiautomatic handgun, brass knuckles, knives, an axe, a machete, paracord, cable ties, straps, and duct tape.
Mr. Graham was indicted on one count of attempted kidnapping and one count of assault. He underwent multiple psychological evaluations and was determined to be competent to stand trial. At his bench trial, Mr. Graham stated on the record that he had decided not to plead not guilty by reason of insanity. His defense argued that at the time of the parking lot incident, Mr. Graham had an abnormal condition of the mind that raised a reasonable doubt as to his intent to kidnap the child.
Mr. Graham was evaluated by one psychologist who testified that at the time of the incident Mr. Graham had a “psychotic break” that caused him to have a distorted perception of reality. This psychologist also testified that there was no evidence that Mr. Graham's “psychotic break” interfered with his ability to act with intent at the time of the incident. Mr. Graham was evaluated by a second psychologist who testified that Mr. Graham was experiencing “psychiatric symptoms” at the time of the incident, which “did not interfere with his … ability to engage in goal-directed, planful behavior” (Graham, p 1106).
The trial court found that Mr. Graham, because of his “impaired perception of reality,” had an abnormal condition of the mind at the time of the incident. However, the trial court did “not find that Mr. Graham's apparent perception of reality raise[d] a reasonable doubt as to his intent to complete the offense of kidnapping” (Graham, p 1106). The trial court found that Mr. Graham engaged in “goal-directed, volitional actions” during the incident and concluded that the state had proved beyond a reasonable doubt that Mr. Graham had the requisite intent necessary for the crime of attempted kidnapping. Mr. Graham appealed to the Supreme Judicial Court of Maine regarding whether the trial court correctly analyzed his mental-abnormality defense.
Ruling and Reasoning
The Supreme Judicial Court of Maine ruled that the trial court correctly analyzed whether Mr. Graham's mental abnormality negated his ability to form the requisite intent for the crime of attempted kidnapping. In Maine, evidence of an abnormal condition of the mind can be used to raise a reasonable doubt as to the existence of formation of requisite intent. The trial court considered Mr. Graham's mental-abnormality defense and determined that the evidence of Mr. Graham's mental abnormality did not create a reasonable doubt to the allegation that he acted with requisite intent to kidnap the child. The trial court ruled that the state had proven beyond a reasonable doubt that Mr. Graham had the required culpable state of mind (i.e., he formed the requisite intent) for the attempted kidnapping and assault of the child.
The Supreme Judicial Court of Maine pointed out that just because a person has a mental condition does not mean that his conduct is not intentional. The statutory definition of intentional conduct focuses on the purposeful nature of the conduct and the actor's awareness of its consequences. The Supreme Judicial Court of Maine stated, “[I]n evaluating whether evidence of the defendant's abnormal mental state raises doubt as to the intentional quality of the defendant's actions, the fact-finder should consider the relationship between the defendant's mental state and evidence that the defendant in fact acted purposefully and appreciated the consequences of his or her actions” (Graham, p 1108). The trial court held that Mr. Graham had a mental abnormality at the time of the incident, but he was acting intentionally at that time, despite the presence of that abnormality. The Supreme Judicial Court of Maine agreed with the way in which the trial court analyzed whether Mr. Graham possessed the requisite intent to commit attempted kidnapping and assault, viewing the evidence most favorable to the state.
Discussion
The holding of State v. Graham illustrates the point that having a mental abnormality at the time of an alleged crime does not automatically preclude a person from having a culpable mental state. An individual can be mentally ill when he commits a crime and still be held fully responsible for the crime, because he knew what he intended to do when he committed the criminal act. Compare this with the affirmative defense of pleading not guilty by reason of insanity. Just because a person may have a mental illness at the time of a crime does not mean that the person does not know the wrongfulness of his acts. In the same way, just because a person may have a “mental abnormality” at the time of a crime does not mean that he lacks intentionality (i.e., lacks the requisite criminal intent) in his acts.
The burden of proof for an insanity plea differs from the burden of proof for showing requisite criminal intent. Although the burden of proving insanity varies by state, it typically rests with the defendant. In contrast, the prosecutor always has the burden of proof with regard to whether a defendant formed requisite criminal intent. State v. Graham is a case in which the prosecution had to prove a culpable mental state for an attempted kidnapping. Attempted crimes, such as attempted kidnapping, are more difficult for the prosecution to prove requisite intent (compared with completed crimes), because the prosecution must show what is actually in the defendant's mind at the time of the crime without the ability to show that the defendant committed the criminal act.
According to Maine's laws, a person who has a mental abnormality at the time of the offense may not be capable of forming requisite intent. Most states allow evidence of a person's mental disorder to be used in assessing a person's culpable mental state at the time of the commission of a crime. Contrast this with Clark v. Arizona, 548 U.S. 735 (2006), a U.S. Supreme Court decision that allowed the state of Arizona to prohibit defendants from introducing evidence of mental illness to rebut evidence of requisite criminal intent. The decision in Clark v. Arizona, 548 U.S. 735 (2006), does not prevent states (e.g., Maine) from using mental health testimony to assist the trier of fact in determining a defendant's ability to form requisite intent. State v. Graham is a clear example of a court weighing whether mental illness rebuts evidence of requisite criminal intent.
The determination of whether a mental abnormality impairs a person's ability to form requisite criminal intent requires a thorough forensic mental health assessment, including an assessment of mental state at the time of the offense. Forensic psychiatrists and psychologists have the skills needed to perform these evaluations to assist the trier-of-fact to answer the ultimate issue in this type of case.
Footnotes
Disclosures of financial or other potential conflicts of interest: None.
- © 2015 American Academy of Psychiatry and the Law