United States v. Karen Cameron

907 F.2d 1051, 31 Fed. R. Serv. 46, 1990 U.S. App. LEXIS 12668, 1990 WL 96281
CourtCourt of Appeals for the Eleventh Circuit
DecidedAugust 1, 1990
Docket88-3816
StatusPublished
Cited by167 cases

This text of 907 F.2d 1051 (United States v. Karen Cameron) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Karen Cameron, 907 F.2d 1051, 31 Fed. R. Serv. 46, 1990 U.S. App. LEXIS 12668, 1990 WL 96281 (11th Cir. 1990).

Opinions

HILL, Senior Circuit Judge:

I. INTRODUCTION

Appellant raises two issues warranting discussion. First, appellant claims that the district court abused its discretion in prohibiting her from raising an insanity defense because she allegedly failed to give notice of her intent to raise such a defense under Federal Rule of Criminal Procedure 12.2(a). Second, appellant argues that the district court incorrectly prohibited her from introducing evidence relating to a “diminished capacity” 1 defense.2

We find that under the unique circumstances of this case the district court abused its discretion in prohibiting appellant from raising an insanity defense. The district court did not err, however, in prohibiting the introduction of unarticulated, general psychiatric evidence of mental abnormality in order to negate specific intent.

A. Procedural History Relating to the Insanity Defense.

On November 13, 1987, Appellant Cameron was charged with participating in a conspiracy to distribute in excess of five grams of “crack” cocaine, in violation of 21 U.S.C. § 846, and with the distribution of five grams or more of “crack” cocaine, in violation of 21 U.S.C. § 841(a)(1) and (b)(l)(B)(iii), and 18 U.S.C. § 2.

On November 25, 1987, defendant filed a “Notice of Intent to Rely on Expert Testimony of Defendant’s Mental Condition” pursuant to subsection (b) of Federal Rule of Criminal Procedure 12.2. Ms. Cameron admits that she did not, at that time, give notice under subsection (a) of Rule 12.2.3

[1055]*1055On December 1, 1987, the district court granted Ms. Cameron’s motion to postpone her trial until March 10, 1988.4

On December 3, 1987, the government filed a demand for reciprocal discovery in which it sought the results of all mental examinations that the defendant planned to introduce at trial. The government’s motion stated, inter alia, that it had become “apparent” that the defendant would at trial “rely on expert testimony relating to a mental disease.”

The government filed a second motion on December 3, 1987, seeking to compel appellant to submit to a psychological examination at the Medical Center for Federal Prisoners (“MCFP”) at Springfield, Missouri. The examination was necessary, according to the government, to “establish that defendant was sane at the time of the charged offense,” in the event that “the defense attempts to raise an affirmative defense” and “[under the assumption that] such testimony should entitle defendant to [a] jury resolution of-her sanity.”

The district court granted the government’s motion but appointed a local psychiatrist, Dr. Arturo Gonzalez, to examine Ms. Cameron. The district court specifically requested that Dr. Gonzalez determine whether the defendant was (1) mentally competent to stand trial, and (2) legally sane at the time she allegedly committed the offense charged. See 18 U.S.C. § 17(a). In a report dated January 13, 1988, Dr. Gonzalez found Ms. Cameron competent to stand trial. Despite the district court’s explicit request that he do so, Dr. Gonzalez did not, however, make any findings regarding the appellant’s mental health at the time she allegedly committed the charged offenses.

On February 1, 1988, appellant filed a motion for a pretrial ruling on whether certain evidence of her “diminished capacity” would be admissable at trial, “[i]n addition to [her] defense of insanity.” (Emphasis added.) On March 3, 1988, the government responded to appellant’s motion. Although it argued against the admissibility of “diminished capacity” evidence, the government made no objection to defendant’s written notice of her intent to rely upon an insanity defense contained within her February 1, 1988, motion—nearly six weeks prior to the date set for trial (March 10, 1988), and several months after the above-described events.

In an unrelated maneuver, on March 2, 1988, appellant made a motion for hospitalization pursuant to 18 U.S.C. § 4244. In essence, appellant sought a hearing pursuant to 18 U.S.C. § 4247(d) to determine whether she would be eligible for hospitalization rather than incarceration in the event that she was found guilty at trial.5 The motion for hospitalization stated that Ms. Cameron had been (1) medically discharged from the military in 1977 and diagnosed as schizophrenic, (2) diagnosed schizophrenic again in 1986 by a psychiatrist in a veteran’s administration hospital, and (3) was receiving outpatient treatment of an undisclosed nature from the psychiatric unit of a veteran’s administration hospital during at least some of the time she allegedly committed the crimes charged.

On March 9, 1988, the government filed a motion in limine to prohibit the defendant from presenting evidence of insanity because (1) there was “nothing described in the medical reports, notes or hospital records (that were disclosed to the government) that, even viewed most favorably to the defendant, would constitute a mental disease or defect within the meaning of 18 U.S.C. § 17(a)”; and (2) “[t]he defendant [1056]*1056ha[d] not filed notice of her intent to rely upon an insanity defense as required by Rule 12.2(a).” Various filings by the government disclose its awareness that Cameron intended to introduce evidence of mental impairment.

The government also argued, as it had in response to Ms. Cameron’s February 1st motion, that the Insanity Defense Reform Act of 1984 precluded the defendant from presenting “diminished capacity” evidence at trial.

The case proceeded to trial on March 10, 1988, at which time co-defendants Edward and Suzanna Burgess moved for a severance on the ground that defendant Cameron’s insanity and/or “diminished capacity” defense would prejudice them. The district court denied the motion for severance and stated that “defendant Cameron’s intentions in that regard [i.e., to present a defense based upon mental impairment] have been manifest for some period of time.... I see no reason why such a motion could not or should not have been filed long before this."

The district court also granted both of the government’s requests for exclusion. The court prohibited defendant Cameron from relying upon an insanity defense because she had failed altogether, according to the court, to provide notice of her intention to rely on an insanity defense as required by Rule 12.2(a). No mention was made by the district court of defendant's written notice in her February 1st motion of an intent to rely upon an insanity defense.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Rose Beth Litzky
18 F.4th 1296 (Eleventh Circuit, 2021)
David Burrows v. State of Tennessee
Court of Criminal Appeals of Tennessee, 2020
State of Tennessee v. Becky Jo Burlison
Court of Criminal Appeals of Tennessee, 2019
United States v. William R. Beamon, Jr.
678 F. App'x 883 (Eleventh Circuit, 2017)
State of Tennessee v. Michael Halliburton
Court of Criminal Appeals of Tennessee, 2016
United States v. John K. Freeman
631 F. App'x 784 (Eleventh Circuit, 2015)
State of Tennessee v. Lesergio Duran Wilson
Court of Criminal Appeals of Tennessee, 2015
United States v. Davis
78 F. Supp. 3d 17 (District of Columbia, 2015)
United States v. Gregory Boyd
773 F.3d 637 (Fifth Circuit, 2014)
United States v. Carolyn Wall
593 F. App'x 128 (Third Circuit, 2014)
Clarence Nesbit v. State of Tennessee
452 S.W.3d 779 (Tennessee Supreme Court, 2014)
United States v. Ging-Hwang Tsoa
592 F. App'x 153 (Fourth Circuit, 2014)
Audrey Broussard v. Wade Maples
535 F. App'x 825 (Eleventh Circuit, 2013)
United States v. Weis
891 F. Supp. 2d 1007 (N.D. Illinois, 2012)
United States v. Michael Herbst
460 F. App'x 387 (Fifth Circuit, 2012)
United States v. McGarity
669 F.3d 1218 (Eleventh Circuit, 2012)
United States v. Patricia Gray
443 F. App'x 515 (Eleventh Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
907 F.2d 1051, 31 Fed. R. Serv. 46, 1990 U.S. App. LEXIS 12668, 1990 WL 96281, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-karen-cameron-ca11-1990.