58 N.Y.2d 104 (1983)
When a defendant raises both the defenses of insanity and extreme emotional disturbance, the jury must be clearly instructed on how each defense applies to the charges, and the failure to do so warrants reversal.
Summary
Carolyn Evans was convicted of manslaughter in the first degree for stabbing Fleeta Evans. At trial, Evans raised the defenses of insanity and extreme emotional disturbance. Psychiatric experts presented conflicting testimony regarding Evans’ mental state. The trial court’s jury instructions were deemed inadequate because they failed to clearly explain how the insanity defense applied to the manslaughter charge and improperly restricted the jury’s consideration of psychiatric testimony. The Court of Appeals reversed the conviction, holding that the jury instructions were erroneous and deprived the defendant of a fair trial, warranting dismissal of the indictment due to the conviction of a lesser included offense.
Facts
Carolyn Evans stabbed Fleeta Evans during a street encounter. Prior to the stabbing, the deceased and her friend had accosted the defendant, with one striking her with an umbrella. Evans, who had a history of mental disturbances, went home, retrieved a kitchen knife, and returned to the location. After further words were exchanged, Evans fatally stabbed the deceased.
Procedural History
Evans was indicted on a single count of second-degree murder. The trial court agreed to also charge manslaughter in the first degree. The jury found Evans guilty of manslaughter in the first degree. The Appellate Division affirmed the judgment of conviction. Evans appealed to the Court of Appeals.
Issue(s)
Whether the trial court erred in its jury instructions regarding the insanity defense and its application to the charge of manslaughter in the first degree, thereby depriving the defendant of a fair trial.
Holding
Yes, because the court erroneously related the insanity defense solely to the charge of second-degree murder and the element of intent with respect to intentional manslaughter, failing to clearly instruct the jury on the scope and effect of the insanity defense as a complete defense relieving the defendant of responsibility for her acts.
Court’s Reasoning
The Court of Appeals found that the trial court’s instructions were confusing and misleading. The court specifically instructed the jury that if they found Evans not guilty of murder by reason of insanity, they should then consider whether she was guilty of manslaughter, creating the impression that the insanity defense related only to the murder charge. The instruction on extreme emotional disturbance failed to reference the insanity defense, impermissibly restricting the jury’s consideration of psychiatric testimony. The court noted that the supplementary charge, in response to the jury’s request for further instructions, erroneously used the “understand[ing] right from wrong” language, resembling the discarded McNaghton Rule. The Court emphasized, “The question of defendant’s sanity at the time of the commission of the homicide * * * was the only real issue in the case and the only one on which the jury, as a practical matter, could have any serious discussion. Above all else on this record, the charge on the law concerning the subject should have been clear and unambiguous. Instead, it was contradictory and must have been perplexing and confusing to an attentive juror.” The Court concluded that the failure to adequately and correctly instruct the jury on the scope and effect of the insanity defense deprived Evans of a fair trial, requiring reversal and dismissal of the indictment because Evans was convicted of a lesser included offense.