RUFFIN V. STATE 270 S.W.3d 586 (2008) CASE BRIEF

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.

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