United States v. Segna (1977)
Nature of Case
Whether the jury should have been given an instruction regarding the definition of wrongfulness to mean moral wrongfulness rather than criminal wrongfulness
Facts of Case
Joseph John Segna, who was not of American Indian descent, was convicted of killing an American Indian police officer on a Navajo Indian Reservation in Arizona. Segna did not dispute committing the crime, but argued that he was not criminally responsible and pleaded not guilty by reason of insanity. Three psychiatrists and one psychologist testified that he suffered from a “fixed delusionary system” and he had a belief that he was a “persecuted Indian”; however, in reality, he was of Italian ancestry. The experts for the defense were all of the opinion that due to his mental disorder at the time of the crime, he was not criminally responsible. Based on the testimony of the experts, lay witnesses, and exhibits, the court concluded that Segna produced substantial evidence that he was not legally responsible for the murder because of a mental disease or defect. The insanity test at that time was “A person is not responsible for criminal conduct if at the time of such conduct as a result of mental disease or defect he lacks substantial capacity either to appreciate the criminality (wrongfulness) of his conduct or to conform his conduct to the requirements of law.” The burden of proof then shifted to the government, and the government had to prove Segna sane beyond a reasonable doubt.
At his trial, the prosecution had several lay witnesses and one expert witness, a psychiatrist, Dr. Gorman. Dr. Gorman was of the opinion that Segna was sane and suffered from “antisocial, psychopathic personality.” Dr. Gorman’s testimony was discredited during cross-examination. During the trial, Segan asked that the jury be given explicit instructions concerning the meaning of wrongfulness to mean moral wrongfulness, rather than criminal wrongfulness. The district judge refused, because he believed that adding the word “moral” would not be beneficial and rather result in confusing the jury. During the prosecution’s closing arguments to the jury, the prosecutor incorrectly instructed the jury that Segna was presumed sane, but in reality the prosecution had the burden of proof. The prosecution stated that the jury must return a guilty verdict “unless you are convinced by scientific evidence the man is sick and doesn’t appreciate the wrongfulness of his acts.” Segna was convicted of the police officer’s murder. Segna then appealed his conviction to the United States Court of Appeals, Ninth Circuit.
Did the United States District Court for the District of Arizona err in finding the defendant sane beyond a reasonable doubt, and in refusing to instruct the jury in regard to the meaning of wrongfulness? Did the prosecutorial misconduct during the trial require the conviction to be reversed and Segna to be given a new trial? Lastly, were some of the district court’s evidentiary findings erroneous?
The United States Court of Appeals, Ninth Circuit denied Segna’s argument that the court erred in finding Segna sane beyond a reasonable doubt, and held that “the evidence was sufficient to permit reasonable jurors to conclude that Segna was legally sane beyond a reasonable doubt.” The appellate court agreed with Segna’s argument that the prosecutor’s argument was erroneous and held “it is highly probable that the prosecutor’s argument materially affected the verdict and thereby seriously prejudiced Segna. This amounts to plain error under Rule 52(b). Accordingly, we reverse and remand for a new trial.”
In regard to Segna’s third argument, that the jury should have been given an instruction regarding the definition of wrongfulness, the appellate court refused to answer whether Segna’s proposed instruction should have been used, and whether an instruction was required to be given. The appellate court decided that this matter could be resolved during the new trial. However, the appellate court did state that “the district court must, when properly requested, instruct on the issue if the record contains evidentiary support for the defendant’s theory that, although he realized the offending act was illegal, because of mental disease he possessed a false belief that the act was morally justified.” The appellate court also stated that they adopted the following meaning of wrongfulness: “In our view, use of the word wrongfulness in the test of legal insanity would exclude from the criminally responsible category those who, knowing an act to be criminal, committed it because of a delusion that the act was morally justified.”
The appellate court stated that in the insanity test, the word wrongfulness has three possible definitions: “contrary to law, contrary to public morality, or contrary to one’s own conscience.” The second definition concerns objective morality and the third, a more subjective version of morality. In the third definition, an individual may appreciate that the act is illegal and contrary to public morality, but believes he is morally justified in his conduct, because of his mental disease or defect. The appellate court felt that the drafters of the ALI and their discussions seemed to point towards the latter definition and so the appellate court adopted the third approach.