consequence instruction in Iowa

2021See Jamgochian, 832 A.2d at 363-64 (noting a potential ineffective-assistance-of-counsel claim when an attorney fails to advise client that community supervision for life would include travel restriction); People v. Monk, 989 N.E.2d 1, 5-6 (N.Y. 2013) (Rivera, J., dissenting) (stating that a plea bargain where defendant does not know that a violation of the special sentence may lead to incarceration is not knowing and voluntary).

2021See Jamgochian, 832 A.2d at 363-64 (noting a potential ineffective-assistance-of-counsel claim when an attorney fails to advise client that community supervision for life would include travel restriction); People v. Monk, 989 N.E.2d 1, 5-6 (N.Y. 2013) (Rivera, J., dissenting) (stating that a plea bargain where defendant does not know that a violation of the special sentence may lead to incarceration is not knowing and voluntary).

2021See Jamgochian, 832 A.2d at 363-64 (noting a potential ineffective-assistance-of-counsel claim when an attorney fails to advise client that community supervision for life would include travel restriction); People v. Monk, 989 N.E.2d 1, 5-6 (N.Y. 2013) (Rivera, J., dissenting) (stating that a plea bargain where defendant does not know that a violation of the special sentence may lead to incarceration is not knowing and voluntary).

2021See Jamgochian, 832 A.2d at 363-64 (noting a potential ineffective-assistance-of-counsel claim when an attorney fails to advise client that community supervision for life would include travel restriction); People v. Monk, 989 N.E.2d 1, 5-6 (N.Y. 2013) (Rivera, J., dissenting) (stating that a plea bargain where defendant does not know that a violation of the special sentence may lead to incarceration is not knowing and voluntary).

2019See State v. Clark, 608 N.W.2d 5, 8-9 (Iowa 2000).

2017In the routing statement for the appellant’s brief, Kirwan asked the supreme court to retain this case to “revisit its opinion” in Becker, 818 N.W.2d at 147–63, in regard to instructing the jury on the consequence of a verdict finding him not guilty by reason of insanity. 16 The argument in Kirwan’s opening brief is directed at the supreme court, asking it “to exercise its supervisory authority over lower courts to permit them the discretion to provide a consequence instruction upon a defendant’s request.” See State v. Dahl, 874 N.W.2d 348, 353 (Iowa 2016) (citing article V, section 4 of the I

2017Id. at 163 (citation omitted).

2017In the routing statement for the appellant’s brief, Kirwan asked the supreme court to retain this case to “revisit its opinion” in Becker, 818 N.W.2d at 147–63, in regard to instructing the jury on the consequence of a verdict finding him not guilty by reason of insanity. 16 The argument in Kirwan’s opening brief is directed at the supreme court, asking it “to exercise its supervisory authority over lower courts to permit them the discretion to provide a consequence instruction upon a defendant’s request.” See State v. Dahl, 874 N.W.2d 348, 353 (Iowa 2016) (citing article V, section 4 of the I

2012Since the instruction at issue in this case has not garnered the support of a majority of jurisdictions, we cannot say that there is a community consensus on this issue such that due process mandates the instruction _____________________________ 683 N.W.2d 399, 407 (S.D. 2004); Robison, 888 S.W.2d at 476–77; State v. Percy, 507 A.2d 955 , 957–58 (Vt. 1986) (discussing and reaffirming the Vermont Supreme Court’s holding in State v. Smith, 396 A.2d 126, 129 (Vt. 1978), to refuse, as a general rule, to require the instruction); Kitze v. Commonwealth, 435 S.E.2d 583, 586 (Va. 1993) (holding that f

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012Va. 1980). 41 jurisdictions which require the instruction have specific statutes mandating the practice. 14 However, a slight majority of states do not require a consequence instruction, or else only allow the instruction where the consequences of a not-guilty-by-reason-of-insanity verdict are inaccurately portrayed to the jury by the prosecutor or defense counsel.15 14Wood, 545 A.2d at 1035–36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 376 A.2d 1111 , 1113–14 (Conn. 1977), but that the instruction is currently required by

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012Va. 1980). 41 jurisdictions which require the instruction have specific statutes mandating the practice. 14 However, a slight majority of states do not require a consequence instruction, or else only allow the instruction where the consequences of a not-guilty-by-reason-of-insanity verdict are inaccurately portrayed to the jury by the prosecutor or defense counsel.15 14Wood, 545 A.2d at 1035–36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 376 A.2d 1111 , 1113–14 (Conn. 1977), but that the instruction is currently required by

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012Va. 1980). 41 jurisdictions which require the instruction have specific statutes mandating the practice. 14 However, a slight majority of states do not require a consequence instruction, or else only allow the instruction where the consequences of a not-guilty-by-reason-of-insanity verdict are inaccurately portrayed to the jury by the prosecutor or defense counsel.15 14Wood, 545 A.2d at 1035–36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 376 A.2d 1111 , 1113–14 (Conn. 1977), but that the instruction is currently required by

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Since the instruction at issue in this case has not garnered the support of a majority of jurisdictions, we cannot say that there is a community consensus on this issue such that due process mandates the instruction _____________________________ 683 N.W.2d 399, 407 (S.D. 2004); Robison, 888 S.W.2d at 476–77; State v. Percy, 507 A.2d 955 , 957–58 (Vt. 1986) (discussing and reaffirming the Vermont Supreme Court’s holding in State v. Smith, 396 A.2d 126, 129 (Vt. 1978), to refuse, as a general rule, to require the instruction); Kitze v. Commonwealth, 435 S.E.2d 583, 586 (Va. 1993) (holding that f

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495 , 497–500 (Me. 2010); People v. Goad, 364 N.W.2d 584 , 589–90 (Mich. 1984) (not requiring the instruction because it would be impossible to fully explain the “consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 246 N.W.2d 48 , 52–53 (Minn. 1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss. 1982); State v. Buckman, 630 P.2d 743,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012State v. Heemstra, 721 N.W.2d 549, 553 (Iowa 2006) (“We review challenges to 11 jury instructions for correction of errors at law.

2012State v. Heemstra, 721 N.W.2d 549, 553 (Iowa 2006) (“We review challenges to jury instructions for correction of errors at law.

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012Additionally, one court specifically held the failure to give the instruction does not make a trial “fundamentally unfair.” Campbell v. State, 515 S.W.2d 453, 456 (Mo.1974). 12 There are many jurisdictions which require a consequence instruction, even though the Due Process Clause is not used to justify the requirement.

2012Wood, 545 A.2d at 1035-36 (noting that, under common law rules, Connecticut courts did not require the instruction, see State v. Holmquist, 173 Conn. 140 , 376 A.2d 1111, 1113-14 (1977), but that the instruction is currently required by statute); Spraggins, 364 S.E.2d at 863 (noting that instruction is required by statute); Cooper v. State, 253 Ga. 736 , 325 S.E.2d 137, 139-40 (1985) (holding a consequence instruction is not necessary because the consequences of the verdict “have no bearing upon the guilt or innocence of the defendant"); Amorin, 574 P.2d at 898-99 ; Alexander, 729 P.2d at 1135

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012Tankersley v. State, 724 So.2d 557, 563-64 (Ala.Crim.App.1998) (requiring the instruction only if the jury has been given the impression that the defendant would go free if acquitted by reason of insanity); State v. Moody, 208 Ariz. 424 , 94 P.3d 1119, 1164 (2004) (en banc); Burns v. State, 323 Ark. 206 , 913 S.W.2d 789, 791 (1996); Aizupitis v. State, 699 A.2d 1092, 1094-95 (Del.1997) ("This Court has decided to adhere to Delaware’s well-established precedents which do not require the trial court to give an instruction to the jury on the effect of a verdict of NGRI [not guilty by reason of in

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,

2012For that reason, we now hold that neither the prosecutor, defense counsel, nor the court may make any comment about the consequences of a particular verdict at any time during a criminal trial.”); State v. Okie, 987 A.2d 495, 497-500 (Me.2010); People v. Goad, 421 Mich. 20 , 364 N.W.2d 584, 589-90 (1984) (not requiring the instruction because it would be impossible to fully explain the "consequences” of an NGRI verdict because they are contingent on future events); State v. Bott, 310 Minn. 331 , 246 N.W.2d 48, 52-53 (1976); Emanuel v. State, 412 So.2d 1187, 1190 (Miss.1982); State v. Buckman,