Eason v. State

Hunt, Justice,

concurring.

I write separately to address Justice Gregory’s analysis of the gradations of mental responsibility for criminal conduct and to disagree with his premise, as well as to comment on Justice Smith’s dissent.

Legally speaking, guilty but mentally ill is not some vague middle ground between sanity and insanity. Instead, that verdict is necessarily predicated upon a finding by the jury that the defendant is legally sane, that is, that at the time of the commission of the crime he knew right from wrong and was not laboring under a delusional compulsion. Once the jury rejects the defendant’s contention that he is *706legally insane, it may nonetheless modify the guilty verdict with “but mentally ill.” On review of such a verdict, the only question before the appellate court is whether “a rational trier of fact could have found that the defendant failed to prove by a preponderance of the evidence that he was insane at the time of the crime.” Brown v. State, 250 Ga. 66, 71-72 (295 SE2d 727) (1982). This is, of course, the same standard of review where the verdict is simply “guilty.”

Contrary to Justice Smith’s contentions, I find this case distinguishable from Stevens v. State, 256 Ga. 440 (350 SE2d 21) (1986). In Stevens, the trial court, after a bench trial, found in a written order that the defendant was laboring under a delusional compulsion which overmastered his will and which caused the criminal act. Its finding on the third element of delusional compulsion that the delusion, if true, would not have justified the act, and his resulting judgment of guilty but mentally ill were reversed by us because we found that the evidence demanded a contrary finding on that third prong in light of the trial court’s other findings. Here, Eason was convicted by a jury which made no such conflicting findings. Thus, its verdict of guilty but mentally ill must be affirmed since the contrary, not guilty by reason of insanity, is not required under the evidence.

In conclusion, while a guilty but mentally ill verdict may be said to add credence to the defendant’s contentions concerning his mental state, it is nonetheless a legal rejection of his insanity plea. We cannot say from the evidence in this case that rational jurors could not find that the defendant failed to prove insanity by a preponderance of the evidence. Brown v. State, supra.