State of Louisiana v. John W. Hatfield, III

CourtLouisiana Court of Appeal
DecidedDecember 14, 2016
DocketKA-0016-0457
StatusUnknown

This text of State of Louisiana v. John W. Hatfield, III (State of Louisiana v. John W. Hatfield, III) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Louisiana v. John W. Hatfield, III, (La. Ct. App. 2016).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

16-457

STATE OF LOUISIANA

VERSUS

JOHN W. HATFIELD, III

**********

APPEAL FROM THE THIRTY-SIXTH JUDICIAL DISTRICT COURT PARISH OF BEAUREGARD, NO. CR-2012-873 HONORABLE C. KERRY ANDERSON, DISTRICT JUDGE

JOHN D. SAUNDERS JUDGE

Court composed of John D. Saunders, Billy Howard Ezell, and D. Kent Savoie, Judges.

AFFIRMED. James R. Lestage District Attorney 36th Judicial District Court Richard F. Blankenship Assistant District Attorney P. O. Box 99 DeRidder, LA 70634 (337) 463-5578 COUNSEL FOR PLAINTIFF/APPELLEE: State of Louisiana

Chad Ikerd Louisiana Appellate Project P.O. Box 2125 Lafayette, LA 70502 (225) 806-2930 COUNSEL FOR DEFENDANT/APPELLANT: John W. Hatfield, III SAUNDERS, Judge.

On February 14, 2013, a grand jury indicted Defendant, John W. Hatfield,

III, for the second degree murder of four-year-old Tanner Bailey. A sanity

commission was appointed on February 26, 2013, to determine whether Defendant

was able to proceed and whether he was sane at the time he committed the murder.

The trial court appointed Dr. Flynn Taylor and Dr. James Anderson to evaluate

Defendant and determine whether he was competent to stand trial.

Dr. Anderson determined Defendant was incompetent to proceed to trial. He

recommended treatment in an inpatient hospital setting and believed Defendant

could be returned to competency with the appropriate treatment. Dr. Flynn could

not give “a real answer as to weather [sic] [Defendant was] fully competent.”

On June 26, 2013, the trial court found Defendant lacked the appropriate

mental capacity to stand trial and ordered him committed to the Feliciana Forensic

Facility. On August 26, 2014, the trial court found Defendant’s competency to

stand trial had been restored. Defendant entered pleas of not guilty and not guilty

by reason of insanity.

A jury found Defendant guilty of second degree murder on March 3, 2016.

The trial court sentenced Defendant to life imprisonment at hard labor without

benefit of parole, probation, or suspension of sentence, to run consecutively to any

other sentence. The trial court also recommended Defendant be placed in a mental

health unit during his prison term.

Defendant now alleges he proved by a preponderance of the evidence that he

was legally insane at the time of the murder, and no rational jury could have found

otherwise. FACTS:

On December 18, 2012, Defendant, a diagnosed paranoid schizophrenic,

stabbed and killed his four-year-old nephew, Tanner Bailey.

ASSIGNMENT OF ERROR:

Defendant contends he proved by a preponderance of the evidence that he

was legally insane at the time of this crime, and no rational juror could have found

otherwise. We disagree.

Under La.Rev.Stat. 14:14:

If the circumstances indicate that because of a mental disease or mental defect the offender was incapable of distinguishing between right and wrong with reference to the conduct in question, the offender shall be exempt from criminal responsibility.

However, in Louisiana there is a legal presumption that the defendant is sane and responsible for his actions. La.Rev.Stat. 15:432; State v. Poree, 386 So.2d 1331 (La.1979). Therefore, to overcome this presumption of sanity, the defendant has the burden of proving by a preponderance of the evidence that he suffered a mental disease or a mental defect which prevented him from distinguishing between right and wrong with reference to the conduct in question. La.Code Crim. Pro. art. 652; State v. Armstrong, 94-2950, pp. 4-5 (La.4/8/96), 671 So.2d 307, 309; State v. Silman, 95-0154, p. 7 (La.11/27/95), 663 So.2d 27, 32; State v. Peters, 94-0283, pp. 8-9 (La.10/17/94), 643 So.2d 1222, 1225-26. Sanity is a factual matter for the jury, to be determined from all of the evidence, both lay and expert, along with circumstances surrounding the events and testimony relating to the defendant’s behavior before, during, and after the crime. State v. Price, 403 So.2d 660, 663-64 (La.1981); State v. Claibon, 395 So.2d 770, 772 (La.1981); State v. Roy, 395 So.2d 664, 668-69 (La.1981). A determination of the weight of the evidence is a question of fact that rests solely with the trier of fact, who may accept or reject, in whole or in part, the testimony of any witness, and if rational triers of fact could disagree as to the interpretation of the evidence, the rational trier’s view of all of the evidence most favorable to the prosecution must be adopted. State v. Silman, 95-0154, p. 12, 663 So.2d at 35.

In reviewing a claim for insufficiency of evidence in an action where the affirmative defense of insanity is raised, the appellate court, applying the standard set forth in Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979), must determine whether under the facts and circumstances of the case, any rational fact finder, viewing the evidence most favorably to the prosecution, could 2 conclude, beyond a reasonable doubt, that the defendant failed to prove by a preponderance of the evidence that he was insane at the time of the offense. State v. Peters, 94-0283, p. 8, 643 So.2d at 1225; State v. Armstrong, p. 4, 671 So.2d at 309; State v. Nealy, 450 So.2d 634, 639 (La.1984).

State v. Williams, 07-1407, pp. 7-8 (La. 10/20/09), 22 So.3d 867, 875-76, cert.

denied, 560 U.S. 905, 130 S.Ct. 3278 (2010).

Defendant contends his circumstances show he could not tell right from

wrong. He had a long history of mental health problems. Doctors at Greenbriar

took him off his regular medication and placed him on a new one. Defendant

stopped taking that medication when he returned home days before the murder. He

made no attempt to harm anyone other than Tanner, who was the object of a

delusion. Defendant’s admission of what he did and his failure to flee or hide

evidence add to the circumstances that show he could not tell right from wrong at

the time of the murder and should have been found not guilty by reason of insanity.

However, the defense presented no expert testimony to opine Defendant was

insane at the time of the offense. Dr. Cantu, Defendant’s treating psychiatrist for

some time prior to the time of the offense, was not qualified to give an opinion

about Defendant’s sanity at the time of the murder. The defense criticized Dr.

Vosburg’s testimony because he saw Defendant only once, more than two years

after the murder. Dr. Vosburg admitted his opinion was only as reliable as the

records and the record-takers, and he wished he “had more exacting” records.

In his appeallate brief, Defendant incorrectly argues Dr. Vosburg “saw

[Defendant] as merely depressed, sleep deprived, suffering with severe mood

swings, and had poor impulse control at the time [he] killed his four-year-old

nephew[,]” rather than as a paranoid schizophrenic. In fact, Dr. Vosburg testified

Defendant’s prescribed mood-stabilizing medication indicated to him “there’s an

affect or a mood component . . . beyond just paranoid schizophrenia . . . . a 3 combination of schizophrenic symptoms and affective or mood symptoms.” Dr.

Vosburg’s expert opinion was that Defendant knew right from wrong when he

murdered Tanner.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
State v. Poree
386 So. 2d 1331 (Supreme Court of Louisiana, 1980)
State v. Armstrong
671 So. 2d 307 (Supreme Court of Louisiana, 1996)
State v. Price
403 So. 2d 660 (Supreme Court of Louisiana, 1981)
State v. Sharp
418 So. 2d 1344 (Supreme Court of Louisiana, 1982)
State v. Silman
663 So. 2d 27 (Supreme Court of Louisiana, 1995)
State v. Roy
395 So. 2d 664 (Supreme Court of Louisiana, 1981)
State v. Claibon
395 So. 2d 770 (Supreme Court of Louisiana, 1981)
State v. Nealy
450 So. 2d 634 (Supreme Court of Louisiana, 1984)

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State of Louisiana v. John W. Hatfield, III, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-v-john-w-hatfield-iii-lactapp-2016.