Blake v. United States

Facts

D robbed a bank and was tried. He claimed insanity but was convicted. D appealed based on the contention that the definition of insanity used by the trial court was outmoded and prejudicial. In 1944, at the age of 21, and while in the Navy, D suffered an epileptic seizure and was thereafter given a medical discharge. He suffered disciplinary problems while in the Navy. He received electro-shock treatment in 1945, and following further mental difficulties in 1945 and 1946, entered a Veterans Administration hospital for a stay of two to three months in 1946. D became a heavy drinker. In 1948 he was admitted to a private psychiatric institution in Connecticut. D received private outpatient care from psychiatrists, and between 1948 and 1954 spent time in at least three private psychiatric institutions and received further electro-shock treatment. From 1955 to 1960, his behavior was characterized by heavy drinking and irrational acts. He began the use of stimulants and drugs. In 1955 he received eight electro-shock treatments. He was adjudged incompetent in 1956 and placed under his father's guardianship to be placed in a private institution in lieu of commitment. He was discharged from the private institution some six months later. He followed his psychiatrist to Indiana and was treated on an outpatient basis for about a year. D was arrested in December 1959 for shooting his second wife. After spending a few days in jail, he was placed in a state mental hospital for several months and was finally placed on probation for the shooting offense. He continued to receive private psychiatric treatment, in and out of hospitals while on probation up to the spring of 1963. D spent six months in 1962 in a Florida state mental hospital after being declared incompetent and certified for treatment. In 1963, D was sentenced to the Florida state penitentiary after being called up for violation of probation on a charge of aggravated assault. He was released on September 14, 1965. While in prison he was hospitalized three or four times; saw the prison psychiatrist, and complained of blackouts. During this period of confinement, he was divorced by his third wife. He married his fourth wife on December 2, 1965. The robbery in question occurred on December 6, 1965. The facts of the robbery are just as bizarre as his life of being in and out of mental institutions. It was committed three hours after an attempt to obtain a legal hearing for a writ of habeas corpus to relieve him of certain state prison release restrictions which kept him from going to the Miami area. He stopped at a bar, had several drinks, and then told the waitress he would be back later with a lot of money. The waitress joked about robbing a bank and D replied it was possible. D had claimed that the bank he robbed had mishandled trust money for him and that quarrel had gone on for some years. D did not case the bank but merely told the driver of the car to stop, he got out and went in demanded money got it and left. He then ordered the driver to leave and then the next day came back to court to press for his petition for the writ. He was arrested. There was expert testimony that d was suffering from the mental disease of schizophrenia, marked with psychotic episodes and that his behavior on the occasion of the robbery indicated that D was in a psychotic episode. There was also expert testimony that he had a sociopathic personality and was not suffering from a mental disease. The district court charge was based on the dictum in Davis v. United States: 'The term 'insanity' as used in this defense means such a perverted and deranged condition of the mental and moral faculties as to render a person incapable of distinguishing between right and wrong, or unconscious at the time of the nature of the act he is committing, or where, though conscious of it and able to distinguish between right and wrong and know that the act is wrong, yet his will, by which I mean the governing power of his mind, has been otherwise than voluntarily so completely destroyed that his actions are not subject to it, but are beyond his control.'

Issues

Rule of Law

Holding and Decision

Legal Analysis

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