United States v. Marvin Ray Huffman

467 F.2d 189, 1972 U.S. App. LEXIS 7562
CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 13, 1972
Docket72-1013
StatusPublished
Cited by7 cases

This text of 467 F.2d 189 (United States v. Marvin Ray Huffman) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Marvin Ray Huffman, 467 F.2d 189, 1972 U.S. App. LEXIS 7562 (6th Cir. 1972).

Opinions

McCREE, Circuit Judge.

This is an appeal from a jury conviction on three counts of an indictment charging that Huffman mailed three letters which threatened the lives of the President and Vice President of the United States, in violation of 18 U.S.C. § 871(a).1 The District Court sentenced Huffman to imprisonment for three concurrent five-year terms pursuant to 18 U.S.C. § 4208(a)(2).

Appellant contends that the evidence does not support the jury’s determination that he possessed the requisite criminal intent; that the jury instruction on intent was erroneous; and that the court did not give counsel an opportunity to object to its instructions after they had been given and before the jury had begun its deliberations as required by Rule 30 of the Federal Rules of Criminal Procedure. Appellant does not deny that he wrote and mailed the letters.

We conclude that the instructions were erroneous and that the court failed to comply with Rule 30. Accordingly, we reverse the conviction and remand the case for a new trial.

Appellant is a man of below average intelligence, and an avowed homosexual. It is undisputed that he has a history of mental disorders and that he was under emotional stress and was deeply disturbed at the time he wrote these letters. He also has a history of repeated criminal activity. He was previously convicted in North Carolina of writing a threatening letter to the President, and as a result of that conviction, he was transferred from a state prison to a federal prison. At the time he wrote the letters for which he was indicted here, he was confined by the United States Army in the stockade at Fort Knox, Kentucky, for having been absent without leave.

During his incarceration at Fort Knox, he was confined, for a period, to a psychiatric ward in Ireland Army Hospital because he had intentionally cut his own wrists three times in the stockade. He characterizes these incidents as suicide attempts, but appellee contends that the cuts were superficial and were intended only to procure his release from the stockade.

The letters were written during June 1971. The first letter, dated June 18, 1971, was addressed to the Vice President and stated that Huffman would kill him if the Vice President did not have Huffman released from the Army within 14 days and did not provide him with [191]*191$100,000 in 20 and 50 dollar bills.2 The second letter, dated June 21, 1971, was addressed to the President. It informed him that Huffman had made plans to kill the Vice President and that he had decided to kill the President two days before killing the Vice President.3 The third letter, dated June 27, 1971, was addressed to the President and stated that Huffman had “made up his mind” to kill the President pursuant to a plan whereby Huffman would become the owner of “at least one-half of the United States.” The letter also threatened the lives of the President’s daughter, the Secretary of State, the Secretary of the Interior, J. Edgar Hoover (the Director of the Federal Bureau of Investigation), and the Vice President. It further stated that Huffman intended to undergo a sex change and to become the first woman President of the United States.4

At trial, Huffman’s only defense was that he was suffering from a mental disturbance at the time he wrote the letters, and that it was so serious that he did not know what he was doing and could not conform his conduct to the re[192]*192quirements of the law.5 In support of this defense, he submitted the testimony of a psychologist, Dr. Curtis L. Barrett, Jr., who had administered several tests of different types to Huffman and had interviewed him twice, on one occasion for about four hours. In rebuttal, the Government submitted the testimony of a psychiatrist, Dr. John D. Trawiek, Jr., who had interviewed Huffman at the Jefferson County Jail on August 25, 1971, for a period of “somewhat over an hour.” The principal purpose of Dr. Trawick’s interview with Huffman was to determine competency to stand trial, but Dr. Trawiek testified that he was also able to form some conclusions about Huffman’s mental state two months earlier.

Both parties submitted written requests for jury instructions on insanity as a defense. In his written request, the Assistant United States Attorney asserted that he followed our decision in United States v. Smith, 404 F.2d 720 (6th Cir. 1968). In that case we expressed approval of the standards of the American Law Institute stated in its Model Penal Code § 4.01 (Official Draft, 1962)6 :

We now elect generally to adhere to the test of criminal responsibility [stated in] the Model Penal Code. We believe it to be a test which a jury will readily comprehend; one which comports with and makes available modern scientific knowledge and one which may serve to aid the continuing development of the federal law.
The questions for jury consideration pertaining to criminal responsibility when defendant offers an insanity defense are as follows:
1. Was he suffering from a mental illness at the time of the commission of the crime?
2. Was that illness such as to prevent his knowing the wrongfulness of his act ?
3. Was the mental illness such as to render him substantially incapable of conforming his conduct to the requirements of the law he is charged with violating ?
A negative finding as to the first question or negative findings as to both the second and third questions would require rejection of the insanity defense. An affirmative finding as to the first question, plus an affirmative finding as to either the second or the third question, would require a jury verdict of “not guilty” because of defendant’s lack of criminal responsibility.
If in the judgment of the court the lay and psychiatric testimony provides no issue in relation to the second [193]*193question, there is no need to submit it to the jury.
We emphasize that by approving the ALI standard and by setting forth the questions above we are not seeking to require judicial instructions in these specific words.

But we specifically stated in a footnote that we did not adopt an additional definition endorsed by the ALI:

We do not, however, adopt the following additional definition endorsed by the ALI: “As used in this Article, the terms ‘mental disease or defect’ do not include any abnormality manifested only by repeated criminal or otherwise anti-social conduct.” Model Penal Code § 4.01(2) (Official Draft, 1962). The purpose of this definitional sentence was obviously to exclude from the definition of insanity “psychopathic personalities” who demonstrate mental abnormality principally by habitual violation of the law.

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Related

State v. England
376 S.E.2d 548 (West Virginia Supreme Court, 1988)
United States v. Frank Sacco and Benjamin Gentile
563 F.2d 552 (Second Circuit, 1977)
United States v. Marvin Ray Huffman
467 F.2d 189 (Sixth Circuit, 1972)

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Bluebook (online)
467 F.2d 189, 1972 U.S. App. LEXIS 7562, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-marvin-ray-huffman-ca6-1972.