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Blake v. United States

407 F.2d 908 (5th Cir. 1969)

tl;dr: In light of science on mental illness and incapacity, a sustainability requirement is an appropriate element of insanity.

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John Joseph Blake appealed his conviction for bank robbery, claiming insanity at the time of the offense as his primary defense. The United States Court of Appeals Fifth Circuit found significant errors in the defense of insanity and the legal standards applicable to it in a criminal trial. The court ordered a retrial with a definition of insanity more attuned to present-day psychiatry concepts. The court also pretermitted several assignments of error unrelated to the insanity defense. The remaining assignments of error include a claim that the evidence created a reasonable doubt as to his sanity at the time of the offense, an allegation that the instructions to the jury on the burden of proof for insanity were confusing and erroneous, and an assertion that the definition of insanity given to the jury was outmoded and prejudicial. The burden of proof is always on the prosecution to establish every element necessary to constitute the crime, including the element of sanity. If there is any evidence supporting the claim of insanity, even slight evidence, the issue must be submitted to the jury. The instructions given to the jury on the burden of proof were in accordance with legal precedent and free of error. Blake's claim that his pretrial incarceration affected his ability to assist his counsel in preparing a defense is without merit. The court cited the Dusky v. United States case, which established the test for competency as having a present ability to consult with a lawyer with a reasonable degree of rational understanding and a rational and factual understanding of the proceedings against him. The district court found Blake competent to understand the proceedings against him and assist in his own defense.

Blake's mental health history includes stays in private psychiatric institutions, outpatient care, electro-shock treatment, heavy drinking, drug use, and irrational behavior. He committed a bank robbery while suffering from schizophrenia and was in a psychotic episode during the robbery. The prosecution had to prove beyond a reasonable doubt that Blake was sane at the time of the robbery, despite evidence of his insanity. The court held that the evidence was sufficient to make a jury question, and the government had the burden of proving Blake's mental capacity. The district court charge on the definition of insanity was based on the Davis v. United States case, which has been followed by this circuit.

The court is reviewing the use of the Davis definition of insanity in a charge, with Blake arguing it was too restrictive and prejudicial, and the government arguing it should be maintained. The court has decided to adopt a new definition of insanity that takes into account current knowledge about mental illness, specifically a substantial lack of capacity standard. The court has adopted the Model Penal Code standard for defining insanity in the circuit, with some modifications based on other circuit opinions. The decision is reversed and remanded for further proceedings.

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Facts & Holding

Facts:The defendant was tried for robbing a bank. He was...

Holding:The judge's instruction was erroneous, because it imposed a complete...

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Blake v. United States

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