United States v. Blake case brief

 

United States v. Blake: Blake was charge with bank robbery under 18 USCA §2113. He was arrested the day after the robbery and when his trial began, the evidence that he committed the robbery was overwhelming. He raises the defense of insanity at the time of the commission of the crime. From 1944 through the time of the bank robbery, Blake’s history has been a mess of heavy drinking, blackouts, incarceration, and confinement in mental health facilities. At the time of the robbery, the psychiatric testimony states that Black was suffering from schizophrenia which was marked with psychotic episodes. Another expert stated that Black was just a sociopath and was not suffering from a mental disease.

• The Davis rule: “insanity” as used in this defense means such a perverted and deranged condition of the mental and moral faculties as to render a person incapable of distinguishing between right and wrong, or unconscious at the time of the nature of the act he is committing, or where, though conscious of it and able to distinguish between right and wrong and know that the act is wrong, yet his will, by which I mean the governing power of his mind, has been otherwise than voluntarily so completely destroyed that his actions are not subject to it, but are beyond his control.
• The court adopts the MPC. “A person, as Blake here, may be a schizophrenic or may merely have sociopathic personality. The evidence could go either way. But, he was not unconscious, incapable of distinguishing right and wrong nor was his will completely destroyed in terms of the Davis definition.

• The Davis Rule is same as M’Naghten except it adds that the actions are uncontrollable. M’Naghten is like extreme emotional distress and provocation but it’s different because in EED all you have to show is that a reasonable person would have been very angry even if you go beyond what that reasonable person would have done. You don’t get off completely. It reduces it to manslaughter. However, with insanity under the Davis rule you have to show that you literally could not have stopped yourself. It has to get to the point where anyone else who would have gone through what he went through would have acted the same way.

MPC and Commentaries

• Those who are irresponsible under the M’Naghten rule are plainly beyond the reach of the restraining influence of the law and their condemnation would be both futile and unjust.

• One shortcoming of the M’Naghten Rule is that it authorizes a finding of responsibility in a case in which the actor is not seriously deluded concerning his conduct or its consequences but in which the actor’s appreciation of the wrongfulness of his conduct is a largely detached or abstract awareness that does not penetrate to the affective level.
• The MPC formulation is based on the view that a sense of understanding broader than mere cognition, and a reference to volitional incapacity should be achieved directly in the formulation of the defense. The resulting standard relieves the defendant of responsibility under two circumstances: (1) when, as a result of mental disease or defect, the defendant lacked substantial capacity to appreciate the criminality of his conduct; (2) when, as a result of mental disease or defect, the defendant lacked substantial capacity to conform his conduct to the requirements of law.
  • A test requiring an utter incapacity for self-control imposes a comparably unrealistic restriction on the scope of the relevant inquiry.
  • 70s view: Durham-Bazelon: You get the defense if your crime was a product of mental disease. What counts as a defect or disease is a question of law, but the rest is a question for juries. Most courts were following this standard until Hinckley.
• Now it has been replaced by the idea that to get the insanity defense you had to have been unable to appreciate your actions.