Jury Instructions for Insanity Verdict

Facts of the Case

On August 29, 2009, Mr. Beatty entered the emergency room at Boston Medical Center covered in blood. He approached a uniformed police officer and stated that he “just snapped” before strangling and sexually assaulting his girlfriend. He provided the name and address of the victim.

Mr. Beatty was able to tell police details about the crime, including his consumption of alcohol and Valium, as well as arguments he had about money with his friend. He recounted the details of strangling the victim and smothering her after noticing her mouth was foaming. Though he told police he left the apartment with knives to “take care of himself,” the psychiatrist who evaluated him in the emergency room determined he did not require inpatient admission. While in the hospital triage unit, he admitted to a nurse to having suicidal ideation but denied visual or auditory hallucinations.

In October 2009, Mr. Beatty was indicted on one count of murder in the first degree and one count of aggravated rape. After a suicide attempt, he was sent to Bridgewater State Hospital (BSH) and diagnosed with major depressive disorder with no psychotic component. After being found not competent to stand trial, his diagnosis was amended to schizoaffective disorder with psychotic delusions and paranoia. In February 2018, after several years of treatment at BSH, a judge found Mr. Beatty competent to stand trial and a jury trial commenced in February 2019.

At trial, the defense argued Mr. Beatty was not guilty by lack of criminal responsibility (NGRI). Against the advice of counsel, Mr. Beatty decided to testify about voices and paranoia on the day of the homicide. A psychologist testifying for the defense asserted that Mr. Beatty was prone to delusions but did not offer an opinion on competency or his general ability to appreciate the wrongfulness of his conduct at the time of the murder. A psychiatrist testifying for the prosecution opined that Mr. Beatty had “no significant psychiatric disorder, showed no signs of auditory hallucinations, and possessed adequate intellectual functioning” (Beatty, p 529). The psychiatrist also opined that Mr. Beatty was able to recognize the wrongfulness of his conduct.

At three separate instances during the trial, defense counsel raised the possibility that Mr. Beatty was not competent to stand trial. Each time, the judge ordered a competency evaluation by a court clinician, who opined Mr. Beatty was competent. As part of jury instructions, the trial judge discussed the consequences of a verdict of not guilty due to lack of criminal responsibility, which conformed to the then-applicable model jury instructions on homicide and included reference to commitment times, known as a Mutina instruction in Massachusetts. The jury found Mr. Beatty guilty on both counts, and he was sentenced to life in prison without parole. Mr. Beatty appealed the finding of competency and the prejudicial nature of the jury instructions regarding the consequence of an NGRI verdict.

Ruling and Reasoning

First, the SJC of Massachusetts found that the trial judge did not abuse his discretion in finding Mr. Beatty competent to stand trial. The SJC noted the three court-ordered competency evaluations during the trial. The SJC reasoned the trial judge sufficiently considered Mr. Beatty’s working relationship with counsel, noting Mr. Beatty “has shown his functionality through this trial,” and “[e]ven if his counsel may feel that [testifying] was not the most prudent choice that he had[,] that was his choice under the law” (Beatty, p 533).

The court further ruled that the trial judge did not err in giving jury instruction regarding the consequences of a verdict of lack of criminal responsibility, which included a reference to time frames for commitment. The defense argued that the court should have omitted any reference to commitment time in jury instructions prior to sentencing, to avoid suggesting the possibility of release after a brief stay in a mental hospital. They argued this instruction unfairly prejudiced the jury against Mr. Beatty.

The court reviewed the state’s Model Jury Instructions on Homicide (2018) and whether they incorporated current case law. First described in Commonwealth v. Mutina, 323 N.E.2d 294 (Mass. 1975), the jury instructions mentioned two time periods after a defendant was found NGRI: an initial 40-day observation period and an initial six-month commitment period. Subsequently, Commonwealth v. Chappell, 40 N.E.3d 1031 (Mass. 2015) considered the problem of juries avoiding NGRI verdicts due to underestimating the true length of confinement and thus considering societal protection insufficient based on this description, when in fact the commitment period could be extended indeterminately if need be. After Chappell, the courts proposed a provisional instruction to omit reference to this observation period and to specifically clarify that the initial six-month commitment could be renewed indefinitely as long as the defendant continued to be mentally ill and dangerous. The court found that the trial judge in Beatty provided instructions “using language virtually identical to the Mutina instruction,” and included the recommended changes outlined in Chappell (Beatty, p 535).

Mr. Beatty argued that the six-month initial commitment time frame should also be omitted from jury instructions for the same reason the court previously recommended omission of the forty-day observation period. But, in Beatty, the court saw no reason to change the recommendation, particularly since an additional instruction was given that the six-month initial confinement could become indefinite. Thus, the trial judge acted without error, as the instructions were reflective of the Chappell and Mutina recommendations.

Discussion

The case of Commonwealth v. Beatty reviewed the potentially prejudicial nature of jury instructions specifying time frames for commitment after a jury finding of NGRI. The court found that the state’s most current Model Jury Instructions on Homicide struck a fair balance between the need to inform the jury of the potential consequence of their verdict with the interest in preventing unfair biases against the defendant, namely that he would be confined for minimal time. It is useful to note that other defendants have argued in favor of having a jury instruction on the consequences of an insanity verdict (Piel J. In the aftermath of State v. Becker: a review of state and federal jury instructions on insanity acquittal disposition. J Am Acad Psychiatry Law 2012; 40: 537-46).

Beatty reviewed the original Mutina standard in Massachusetts, which included a 40-day observation and initial six-month commitment advisement, and the proposed changes to the standard as outlined in Chappell, which removed instruction of the 40-day observation and clearly specified the six-month commitment could be renewed indefinitely. By agreeing with the trial judge’s instructions, which used the language of Chappell, the court recognized that it is possible to strike a balance to provide useful jury instruction. The court acknowledged that a commitment timeframe is not de facto prejudicial, especially when clarification is provided to the potentially indefinite nature of commitment, as long as the defendant remains mentally ill and dangerous.

The case is instructive for forensic psychiatrists who may be asked to assess criminal responsibility or assist courts in disposition. An often-discussed concern about jury psychology is the jury’s concern that a person who committed a serious homicide may be released after a short period of time. Beatty illustrates one jurisdiction’s satisfaction that steps can be taken to minimize prejudice from instructions regarding commitment times following an NGRI verdict while remaining necessarily informative.