McCall v. State

408 N.E.2d 1218, 273 Ind. 682
CourtIndiana Supreme Court
DecidedAugust 21, 1980
Docket977S718
StatusPublished
Cited by9 cases

This text of 408 N.E.2d 1218 (McCall v. State) is published on Counsel Stack Legal Research, covering Indiana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCall v. State, 408 N.E.2d 1218, 273 Ind. 682 (Ind. 1980).

Opinions

PRENTICE, Justice.

Defendant (Appellant), together with others, was found guilty of felony murder and premeditated murder, in connection with the murder of Richard Wozniak. He was sentenced to life imprisonment upon the felony murder verdict, while sentencing was withheld upon the premeditated murder verdict. This direct appeal presents the single issue of whether or not the court erred in refusing to permit one of Defendant’s witnesses to testify.

In advance of trial, Defendant gave notice of his intent to present an insanity defense; and pursuant to Ind.Code § 35-5-2-2 (Burns 1975), the trial court appointed two psychiatrists to examine him. These psychiatrists were called to testify out of the order provided by the statute, but without objection of the defendant. Both testified that when they attempted to interview the defendant, he announced that he had nothing to say to them and refused to answer their questions. Both, however, had examined the defendant previously, and both testified that from such prior examinations and from hospital records, they had opinions as to Defendant’s sanity at the time of the crime and that in their opinions, he was then sane.

The first witness called by the defense was Arthur A. Ludwig, who was called to give testimony relating to Defendant’s sanity. The State objected to Ludwig’s being permitted to testify, citing Defendant’s refusal to cooperate with the court-appointed psychiatrists and the case of Lee v. County Court of Erie County, (1971) 27 N.Y.2d 432, 318 N.Y.S.2d 705, 267 N.E.2d 452, cert. den., 404 U.S. 823, 92 S.Ct. 46, 30 L.Ed.2d 50.

The controversy as to whether or not the witness could testify centered upon whether Ludwig would be testifying as a lay witness or as an expert, because the holding in Lee v. County Court of Erie County, supra, was that where the defendant had refused to submit to a court ordered psychiatric examination, his offer of psychiatric testimony was properly rejected.

Voir dire examination was had and revealed that Ludwig was a professional family counselor employed by a community service organization, held numerous academic degrees and had had extensive schooling in law, sociology, psychology and psychiatry. It was further disclosed that Ludwig’s contacts with the defendant and his family, which had spanned a period of approximately thirteen years, had not been a business or social relationship but had been in his professional capacity as a family counselor provided by a community service organization.

The trial court, upon the foregoing testimony, concluded that Ludwig would be tes[1220]*1220tifying as an expert witness and, upon that basis, he was not permitted to testify. We do not approve of the holding in the Lee case, but even if this were not so, we find it so distinguishable from the case before us as to be an unsatisfactory basis for the trial court’s ruling.

In the New York case, Lee pleaded not guilty by reason of insanity to two charges of murder. Conflicting psychiatric opinions were in evidence at this trial, and he was found guilty. On appeal, the convictions were set aside and a new trial ordered upon the grounds that the state had not proven sanity beyond a reasonable doubt and that the verdict was against the weight of the evidence.

On re-trial, Lee again pleaded insanity. The court sustained a state’s motion for a mental examination, but Lee, asserting his prerogative not to incriminate himself, refused to submit to such examination. He was found to be in contempt of court, but the contempt order was reversed.

The trial court again ordered that Lee be examined and further ordered that in the event he did not cooperate, his insanity plea would be stricken and he would be denied the right to call psychiatric witnesses. Lee did refuse to answer the psychiatrists’ questions, and the sanctions mentioned were imposed.

Other questions were presented in the review of the sanctions order upon a petition for a writ of prohibition. Our interest in the case, however, is that the Court of Appeals held: (1) The privilege against self-incrimination does not obtain to preclude a mental examination, where an insanity plea has been interposed. (2) Striking the defendant’s plea was not a proper sanction, since the defendant’s capacity to commit the crime was put in issue by his plea, not by his availability for examination. (3) Since such examinations are the most effective aid to a determination of the merits of the defense, a defendant who chooses to deprive the trier of fact of such an essential source of evidence should not be permitted to offer psychiatric evidence (evidence of the same character as that thwarted) at trial. (4) Other relevant evidence upon the issues should be admitted. (5) If other evidence of insanity is presented, the trial court should apprise the jury of Lee’s failure to cooperate and instruct that such failure should be considered by them in determining the merits of the defense.

Our dissatisfaction with the Lee determination is that if a defendant is, in fact, insane or incompetent to stand trial, such an infirmity may just as likely extend to his seemingly irrational refusal to cooperate as to the anti social conduct that prompted the criminal charges. The problem obviously has no perfect solution, but since the issue of insanity becomes the most vital issue, if not the only one, in such a case and must ultimately be determined by the jury, it seems that the relevant competent evidence should not be precluded, for whatever reason.

The right of the trial court to impose sanctions to enforce compliance with orderly procedures is not questioned. But, due process of law simply cannot tolerate a procedure that imposes sanctions that cut out the very heart of a legally acceptable defense, for conduct, the accountability for which is closely aligned with the central issue at trial.

It has been suggested that the trial court’s action was consistent with our holding in State ex rel. Kiritsis v. Marion Probate Court, (1978) Ind., 381 N.E.2d 1245. In Kiritsis, however, there are marked differences. Kiritsis was a contempt of court matter, following a hearing. Further, it stemmed from a civil commitment proceeding arising from a verdict of not guilty by reason of insanity. Neither criminal nor quasi-criminal sanctions were at stake. The case before us is more akin to Haskett v. State, (1970) 255 Ind. 206, 263 N.E.2d 529, which was distinguished in the majority opinion in State ex rel. Kiritsis, supra.

The recognition of insanity as a defense to criminal charges was recognized at common law simply because one who suffers from insanity cannot, in a legal sense, entertain a criminal intent. A statute providing that insanity would be no defense would be invalid. Ingles v. People, (1933) 92 Colo. [1221]*1221518, 22 P.2d 1109.

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McCall v. State
408 N.E.2d 1218 (Indiana Supreme Court, 1980)

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Bluebook (online)
408 N.E.2d 1218, 273 Ind. 682, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccall-v-state-ind-1980.