People v. Mosely, 19 N.Y.2d 67 (1966)
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Evidence of a defendant’s mental condition, even if not sufficient to establish legal insanity, is admissible during the sentencing phase of a capital trial as a mitigating factor.
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Summary
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Mosely was convicted of first-degree murder and sentenced to death. At the sentencing phase, the trial court refused to admit psychiatric testimony regarding Mosely’s mental state, arguing that the jury had already determined he was legally sane. The New York Court of Appeals reversed, holding that while legal sanity had been established for the purpose of criminal responsibility, evidence of mental illness, even if not rising to the level of legal insanity, was relevant and admissible during sentencing as a mitigating factor. The Court remanded the case with instructions to impose a life sentence.
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Facts
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Mosely confessed to killing, robbing, and attempting to rape Katherine Genovese. At trial, he pleaded not guilty and not guilty by reason of insanity, but his only defense was insanity; he did not dispute committing the crime. During the sentencing phase, after the People presented evidence of aggravating circumstances (prior assaults), Mosely’s counsel sought to introduce psychiatric testimony to show that, while not legally insane, Mosely’s mental illness impaired his self-control.
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Procedural History
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Mosely was convicted of first-degree murder in the Supreme Court, Queens County. Following the guilty verdict, a separate sentencing proceeding was held, where the jury recommended the death penalty. The trial court refused to admit psychiatric testimony during the sentencing phase. Mosely appealed directly to the New York Court of Appeals.
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Issue(s)
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Whether, in a bifurcated capital trial, evidence of a defendant’s mental condition, not amounting to legal insanity, is admissible during the sentencing phase as a mitigating circumstance, even after the jury has found the defendant legally sane.
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Holding
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Yes, because evidence of a defendant’s mental condition is relevant to the sentencing determination, even if it does not establish legal insanity. The sentencing phase allows for the consideration of mitigating factors beyond the narrow definition of legal sanity.
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Court’s Reasoning
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The Court of Appeals reasoned that the statute governing capital sentencing proceedings (§ 1045-a of the Penal Law) allows for the presentation of evidence relevant to sentencing, including the defendant’s background, history, and any mitigating circumstances. The Court emphasized the broad language of the statute, which allows for the admission of “any relevant evidence, not legally privileged.” The court stated, “As defendant argues, a finding of legal sanity should not estop him from producing evidence at the sentencing hearing that he is ‘medically insane’… [E]vidence may be presented by either party on any matter relevant to sentence including, but not limited to, the nature and circumstances of the crime, defendant’s background and history, and any aggravating or mitigating circumstances.” The court drew a distinction between “legal insanity” and “medical insanity,” stating that the jury should be allowed to consider whether anything concerning the “defendant’s background and history” might move the jury to extend mercy. It cited the Model Penal Code’s inclusion of