Pratt v. State

387 A.2d 779, 39 Md. App. 442, 1978 Md. App. LEXIS 216
CourtCourt of Special Appeals of Maryland
DecidedJune 7, 1978
Docket857, September Term, 1977
StatusPublished
Cited by18 cases

This text of 387 A.2d 779 (Pratt v. State) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pratt v. State, 387 A.2d 779, 39 Md. App. 442, 1978 Md. App. LEXIS 216 (Md. Ct. App. 1978).

Opinion

Thompson, J.,

delivered the opinion of the Court.

The appellant, Margaret Melton Pratt, was convicted in the Circuit Court for Montgomery County of murder in the second degree and use of a handgun in the commission of a crime of violence. A fifteen year sentence, seven of which were suspended, was imposed on the murder charge along with a concurrent five year sentence for the handgun conviction.

The murder scenario which led to this appeal began on October 22, 1976 when appellant removed a .32 caliber automatic pistol from her husband’s business vault. 1 At that time she was emotionally distressed and planned to use the gun to commit suicide. After removing the weapon appellant went home, stopping only at a local grocery store to purchase some food for the evening meal. When she arrived home, her husband, William Pratt, who had left work early because of illness, was watching television. Appellant prepared the evening meal and after dinner she and her husband spent an uneventful evening watching television before retiring for the night.

Appellant could not sleep thinking about her contemplated suicide and the consequences of such an act on her husband because she handled the family finances, and tended to his personal needs which were many because of general ill health. There was also some question as to the financial position of the business which worried her. At approximately 7:00 the next morning, after a sleepless night, appellant entered her husband’s bedroom, placed a gun against his head, and shot him. After the initial shot was fired Mr. Pratt began to breathe erratically so appellant fired a second shot to end any possible suffering.

*445 After the shooting, appellant packed an overnight bag and traveled to the farm of friends near Front Royal, Virginia. Her dog was buried on the farm and she spent two or three hours praying at its gravesite. As the friends were not at home, she spent the night in a nearby motel before returning to her home the next day. When appellant arrived home, she wandered around in her car visiting the neighborhood in which she and her husband formerly lived. Realizing she would eventually be apprehended, she went to the police and informed them of her crime. After the police verified the commission of the murder, appellant was formally arrested and ultimately transported to Springfield Hospital Center for psychiatric evaluation.

During the trial the defense did not contest the accusation that appellant had killed her husband, but contended she was insane at the time of the crime. In support of her contention appellant presented two psychiatrists, Dr. Gerald Polin and Dr. Leon Yochelson. They testified that at the time of the crime appellant was suffering from a mental illness and lacked substantial capacity to conform her conduct to the requirements of the law.

In order to counter this testimony the State produced three psychiatrists. All expressed the opinion that appellant was suffering from a mental disorder at the time of the offense; two of the three psychiatrists felt she was legally responsible for her act.

On appeal appellant attacks the validity of her convictions, contending the trial judge committed reversible error in:

(1) Admitting the testimony of Dr. Brian Crowley, one of the State’s psychiatrists, who originally examined appellant at the request of defense counsel;
(2) Refusing to admit testimony corroborative of the factual basis of the opinions given by the defense psychiatrists, even though the State attacked their basis of knowledge;
(8) Refusing to admit a video tape of an interview between appellant and Dr. Polin;
*446 (4) Admitting a report written by Dr. McClelland stating appellant was criminally responsible for her acts, after he was unable to express an opinion on the question at trial;
(5) Unduly restricting cross-examination of a police officer concerning the amount of money appellant had at the time of her arrest;
(6) Admitting pictures of the body of the deceased; and
(7) Denying her right to argument of counsel regarding a possible recommendation of mercy by the jury.

I Dr. Brian Crowley’s Testimony

One of the three psychiatrists presented by the State, Dr. Crowley, had originally been retained by the defense. Dr. Crowley testified that although appellant was suffering from a mental disorder at the time of the offense, she did not lack substantial capacity to conform her conduct to the requirements of the law. Appellant mounts a multifaceted attack on the admission of this testimony arguing it should have been excluded on the grounds of: (1) the attorney-client privilege, (2) the psychiatrist-patient privilege, or (3) the work product doctrine. We conclude admission of the testimony violated the attorney-client privilege so we will not discuss the other arguments in any detail. 2

The attorney-client privilege was defined in Harrison v. State, 276 Md. 122, 135, 345 A. 2d 830, 838 (1975) as follows:

“ ‘(1) Where legal advice of any kind is sought (2) from a professional legal adviser in his capacity as *447 such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his insistence permanently protected (7) from disclosure by himself or by the legal adviser, (8) except the protection be waived.’ ” Quoting 8 J. Wigmore, Evidence § 2292 at 554 (McNaughton rev. 1961).

The theory behind the creation of the privilege is that a lawyer can act effectively only when he is fully advised of the facts and the client’s knowledge that a lawyer cannot reveal his secrets promotes full disclosure. Harrison v. State, supra, 276 Md. at 133-134, 345 A. 2d at 837; Trupp v. Wolff, 24 Md. App. 588, 608-609, 335 A. 2d 171, 183-184, cert. denied, 275 Md. 757 (1975). The privilege is not confined in scope to communications made solely between an attorney and his client but includes communications made to agents employed by the attorney, such as a stenographer, secretary, clerk, or any employee necessary for effective operation. 8 J. Wigmore, Evidence § 2301 at 583; C. McCormick, Handbook of the Law of Evidence § 91 at 188-189 (2d. ed. E. Cleary 1972).

In cases where a question arises concerning a client’s criminal responsibility for an act, a psychiatrist is indispensable for his help in the planning and preparation of the defense as well as his testimony at trial. The attorney could hardly explore the basis of adverse testimony intelligently, without such help. See United States v. Taylor, 437 P. 2d 371, 377 n.9 (4th Cir. 1971); United States v. Alvarez, 519 F. 2d 1036, 1046 (3rd Cir. 1975); United States ex rel. Edney v. Smith, 425 F. Supp. 1038, 1047-1048 (E.D.N.Y. 1976), aff’d mem. 556 F.

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Bluebook (online)
387 A.2d 779, 39 Md. App. 442, 1978 Md. App. LEXIS 216, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pratt-v-state-mdctspecapp-1978.