People v. Wood, 393 N.Y.S.2d 904 (N.Y. 1977)

A defendant who refuses to cooperate with psychiatric examinations may be precluded from introducing psychiatric testimony to support an insanity defense; non-psychiatric evidence of insanity, standing alone, is insufficient to create a jury question when the defendant declines to raise the insanity issue.

Summary

Wood was convicted of homicide. He attempted to present an insanity defense, but refused to cooperate with psychiatric evaluations. The trial court then precluded him from presenting psychiatric testimony regarding his insanity. Wood argued that his “bizarre” courtroom behavior and the “motiveless” nature of the crime constituted enough evidence to warrant consideration of his insanity by the jury. The New York Court of Appeals held that the trial court properly precluded the psychiatric testimony and removed the insanity issue from the jury because Wood refused psychiatric evaluations and offered no direct evidence of insanity.

Facts

Wood was accused of committing homicide. During the trial, his counsel sought to present a defense of insanity. Wood stated that he did not want to raise the insanity defense and refused to cooperate with both the defense and prosecution psychiatrists. Wood’s courtroom behavior was described as “bizarre.” One of the homicide victims had used a racial slur against Wood, and the other victim attempted to stop Wood from fleeing the scene.

Procedural History

The trial court precluded Wood from introducing psychiatric testimony to support his insanity defense. The trial court instructed the jury that the presumption of sanity had not been overcome. Wood appealed, arguing that his courtroom behavior and the nature of the crime were sufficient evidence of insanity. The Appellate Division affirmed the trial court’s decision. Wood then appealed to the New York Court of Appeals.

Issue(s)

Whether the trial court erred in precluding the defendant from introducing psychiatric testimony to support his insanity defense, given his refusal to cooperate with psychiatric evaluations?

Holding

No, because the defendant refused to cooperate with psychiatric examinations and presented no direct evidence of insanity.

Court’s Reasoning

The Court of Appeals relied on Matter of Lee v County Ct. of Erie County, 27 NY2d 432, 443, which held that a defendant cannot offer psychiatric evidence about their sanity if they refuse to submit to an examination by a prosecution psychiatrist. The court distinguished between psychiatric and non-psychiatric evidence. The court acknowledged that non-psychiatric evidence, such as the defendant’s courtroom behavior and the nature of the crime, *may* be relevant to the defendant’s sanity if the issue of sanity has been raised. However, it held that this type of evidence, standing alone without other proof, is not enough to create an issue of fact for the jury when the defendant declined to raise the issue himself. The court noted that, although the defendant may introduce competent nonpsychiatric evidence bearing on his sanity, the prosecution can then reply with nonpsychiatric evidence or with psychiatric testimony based on observations of the defendant in the courtroom. For example, the prosecution could have presented medical testimony that the appellant’s courtroom behavior was feigned. Because there was no direct evidence of insanity and the defendant declined to raise the issue, the trial court acted properly.