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Blake v. United States

(1969)

United States Court of Appeals for the Fifth Circuit - 407 F.2d 908

tl;dr:

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

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Facts & HoldingBlake v. United States case brief 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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Majority opinion, author: BELL, Circuit Judge:
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The defendant in a bank robbery case claimed insanity as a defense, but the court ordered a retrial due to errors in the definition of insanity used in the original trial. The errors were related to confusing and erroneous jury instructions on the burden of proof for insanity and an outdated and prejudicial definition of insanity given to the jury. The legal standard for insanity in criminal cases was established in Davis v. United States, which requires the prosecution to exclude the hypothesis of insanity beyond a reasonable doubt. The issue of insanity should be determined by the jury from all of the evidence, not just the opinion of experts, as established in Mims v. United States. The defendant's claim that his pretrial incarceration affected his mental state and ability to assist his counsel was found to be without merit. The case involves a review of the Davis definition of insanity and whether the district court committed reversible error by giving it in charge. The federal courts of appeals have examined how to adapt the definition of insanity to incorporate the latest medical science knowledge when applying the insanity defense.

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Blake v. United States

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