RUFFIN V. STATE
270 S.W.3d 586 (2008)
NATURE OF THE CASE: Ruffin (D) appealed a conviction and affirmation by the court of
appeals of first degree aggravated assault on grounds trial judge excluded testimony by D's
psychologist about the existence and severity of his mental disease and delusions, ruling
that such expert testimony is admissible only when the defendant is accused of homicide or
pleads insanity.
FACTS: D's neighbors called the Sheriff's Department to report gunshots from D's
property. Deputy Carol Brown had known D and his family for more than ten years and had once
worked at his skating rink as a security guard. A month before D's wife, had told Carol that
D's mental health was deteriorating. Deputy Brown had informed the sheriff's office of D's
condition, so that evening two officers were dispatched to investigate the gunshots. Two
dogs ran up to them, one was bloody and looked like it had been shot. They heard gunshots
from inside and, shortly thereafter, they heard D yelling from the woods, 'Get the hell out
of here!' A few seconds later, they heard more shooting, so they ran back to Carol's patrol
car, took cover behind the car door, and radioed for assistance. The wounded dog leapt into
the patrol car and wouldn't get out. He kept stepping on the brake pedal, which turned on
the brake lights and illuminated the officers hiding behind the patrol car door. D shouted,
'Carol, get the hell out of here before you get hurt.' D kept yelling. He repeatedly
shouted, 'I'm declaring marshal [martial?] law. Carol, get out of here.' D sounded bizarre
and irrational. Throughout the night, appellant sporadically shot at the officers, but
injured no one. Many officers arrived at the scene. Eventually he was talked outside and
arrested. Several lay witnesses testified concerning D's mental status. D had become
obsessed with the color orange and thought that everything should be orange. He talked to
the television set and thought that it talked back. He would pull his cigarette lighter out
and say, 'Okay, Johnny, I know you're listening to me,' and stick it back in his shirt
pocket. He took all of the appliances out of the house because they were bugged, and he wore
a T-shirt with aluminum foil on it to protect himself from receiving signals from the tower.
HIs wife finally moved out of their home in March. When she talked to D the day before the
standoff and he admitted that he needed to see a doctor, she agreed to come back home and
help. Dr. William Lee Carter, who said that, in his professional opinion, D had fallen into
a deep depression in the months before the standoff and had become psychotic. He began to
suffer from delusions, paranoid thinking, and irrationality. Dr. Carter had twice seen D in
the county jail after the standoff, and then saw him three more times in his office. Dr.
Carter explained that a person who is delusional typically believes that his delusions are
true. And a person who is experiencing paranoia has beliefs that people are out to get him,
a lot of suspiciousness, considerable mistrust. D was suffering from psychotic symptoms.
After this proffer, the trial judge excluded Dr. Carter's testimony because [t]he insanity
defense is what is indicated and dictated as our way of determining the capacity of the
defendant to make a specific mens rea. The procedure for doing that is through the insanity
defense. D was convicted. On appeal, D claimed that the trial court abused its discretion in
excluding Dr. Carter's testimony that, because of mental illness and delusions, D did not
know that he was shooting at law-enforcement officers. The court of appeals concluded that
evidence of a mental illness or defect that negates the mens rea of an offense is admissible
only in a murder trial.
ISSUE:
RULE OF LAW:
HOLDING AND
DECISION:
LEGAL ANALYSIS:
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