Evidence that the defendant suffered from a mental disease or defect is admissible to prove whether the defendant had the kind of culpable mental state required for commission of the offense charged.
A defendant was not entitled to a specific instruction informing the jury that he had placed in issue his mental capacity to form the kind of mental state necessary to establish the commission of the alleged offense. Robinson v. State, 269 Ark. 90, 598 S.W.2d 421 (1980).
A trial judge need not give an instruction with regard to the defendant's possession of the kind of culpable mental state required for the commission of the offense charged in addition to giving an instruction on the issue of mental disease or defect. Westbrook v. State, 274 Ark. 309, 624 S.W.2d 433 (1981).
Trial court properly refused to instruct the jury on defendant's mental state because the requested instruction was a modified version of the model instructions and the jury had been instructed regarding the state's burden of proof and the elements of first-degree murder and lesser offenses so that the instruction was effectively given.
Ross v. State, 96 Ark. App. 385, 242 S.W.3d 298 (2006).
Purposely.
Where defendant was found guilty of first-degree murder and attempted first-degree murder, the trial court did not abuse its discretion in excluding certain expert testimony regarding defendant's capacity to form intent. The expert's report did not state that defendant lacked the capacity to form intent, only that it was impacted or impaired, and the expert also opined that defendant's psychotic disorder did not render him unable to appreciate the criminality of his conduct or to conform his conduct to the requirements of the law. Furthermore, there was ample evidence of purposeful conduct where defendant left a bar and returned with a shotgun that he used against the victims.
Edwards v. State, 2015 Ark. 377, 472 S.W.3d 479 (2015).
Relevancy.
The nature, extent and location of wounds were relevant and material on the questions of intent and state of mind and, even if the mental disease or defect did not constitute a defense, evidence of it was relevant on the question of his culpable mental state and especially on the element of premeditation. Campbell v. State, 265 Ark. 77, 576 S.W.2d 938 (1979).
Trial court abused its discretion in excluding the proffered testimony of defendant, defendant's mother, and his friend about his mental disease, because it was directly relevant to the requirement that the State prove, beyond a reasonable doubt, that defendant purposely kidnapped and battered his victims, and thus admissible under this section.
Brown v. State, 2016 Ark. App. 616, 509 S.W.3d 671 (2016).
Bruner v. State, 2013 Ark. 68, 426 S.W.3d 386. · cites it 4ד2 Specifically, appellants contend that the reports should have been admitted to assist the jury in determining whether they acted “knowingly” in causing serious physical injury to the child, as required for the commission of first-degree battery under section 5-12-201(a)(9).…”
Davasher v. State, 823 S.W.2d 863 (Ark. 1992). · cites it 2דSee Ark.Code Ann. § 5-2-303, et seq. (1987) and (Supp.”
Marcyniuk v. State, 2010 Ark. 257, 373 S.W.3d 243. · cites it 2דFurthermore, Ark.Code Ann. § 5-2-303 (Repl.2006) allows the admission of evidence that the defendant suffered from a mental disease or defect to prove whether the defendant had the requisite culpable mental state required for the commission of the offense.”
Bankston v. State, 205 S.W.3d 138 (Ark. 2005). · cites it 2ד2d 752 , and Ark. Code Ann. § 5-2-303 (Repl. 1997), which provides: “Evidence that the defendant suffered from a mental disease or defect is admissible to prove whether he had the kind of culpable mental state required for commission of the offense charged.”
Brown v. State, 2016 Ark. App. 616, 509 S.W.3d 671. · cites it 16דIn response, Brown’s counsel argued that evidence of Brown’s mental disease was relevant and admissible under Arkansas Code Annotated section 5-2-303, which permits such evidence on the issue of | swhether Brown had the culpable mental state required for the commission of the…”
Catlett v. State, 900 S.W.2d 523 (Ark. 1995). · cites it 4ד” Ark. Code Ann. § 5-2-303 (Repl. 1993). Appellant argued at trial that he should be acquitted because he could not form a “premeditated and deliberated purpose,” the required element for a capital murder conviction.”
Copeland v. State, 37 S.W.3d 567 (Ark. 2001). · cites it 2דCopeland’s attorney, during his arguments to the court on this issue at the guilt phase, referred several times to the prior testimony of Dr.”
Edwards v. State, 2015 Ark. 377, 472 S.W.3d 479. · cites it 8ד” Ark. Code Ann. § 5-2-303 (Repl. 2013). In Stewart, 316 Ark.”
Ford v. State, 976 S.W.2d 915 (Ark. 1998). “§ 5-2-303 (Repl. 1997), also provided that evidence of mental disease or defect was admissible to prove whether the accused had the kind of mental state required for commission of the offense.”
Ross v. State, 242 S.W.3d 298 (Ark. Ct. App. 2006). · cites it 4ד§ 5-2-303 , which generally provides that evidence that a defendant suffered from a mental disease or defect is admissible to prove whether he had the kind of culpable mental state required for commission of the offense charged.”
Minor Child v. State of Arkansas, 2023 Ark. App. 592, 680 S.W.3d 787. · cites it 2דMC argues that under these precedents, Melinda should have been “allowed to testify using the language of [MC’s] diagnoses in her testimony and how this affected her mental state.”
James D. Shaw v. Commonwealth of Virginia, 896 S.E.2d 399 (Va. Ct. App. 2024). “The American Bar Association adopted a similar standard, permitting “mental condition” evidence if it “tends to show the defendant did or did not have the mental state required for the offense.” Am. Bar Ass’n, Criminal Justice Standards on Mental Health 47 (2016).”
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