MARC SANFORD EASON, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Marc Sanford Eason appeals his conviction for two counts of first degree murder, claiming he was incompetent to stand trial and insane at the time of the offense due to a prior adjudication of insanity in Michigan. The Florida appellate court affirmed the conviction, holding that the state presented sufficient evidence to overcome the presumption of insanity that arises from a prior adjudication.
The court held that the state presented sufficient evidence at each stage of the proceedings to overcome the presumption of insanity that arises from Eason's prior adjudication. The testimony of two court-appointed experts established competency to stand trial; the testimony of Detective Martinez and Dr. Jaslow established that Eason understood his Miranda rights and gave a voluntary confession; and the jury's verdict, supported by sufficient evidence in the record, found Eason sane at the time of the offense.
[1] A prior adjudication of insanity creates a presumption that the accused remains insane, which attends all stages of a criminal proceeding.
[2] The presumption of insanity arising from a prior adjudication is not conclusive and may be overcome by the prosecution.
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Join FLexlaw to unlock all legal intelligence“where the accused has been previously adjudged insane, there is a presumption that he is still insane”
Establishes the legal rule that a prior adjudication of insanity creates a rebuttable presumption of continued insanity that applies throughout all stages of criminal proceedings.
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Join FLexlaw to unlock all legal intelligenceEason had been previously adjudicated insane by a Michigan court and committed to a state mental hospital, from which he escaped without ever being di…
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PER CURIAM.
The defendant appeals his conviction of two counts of first degree murder in the deaths of Donna and Ronald Fulks. We affirm.
The main focus of the defense at trial and on appeal is the sanity of the defendant. The defense argues that because of the defendant’s prior adjudication of insanity, he was incompetent to stand trial, unable to give a voluntary confession, and entitled to an acquittal by reason of insanity-
It is undisputed that prior to the murders, Eason had been adjudicated insane by a Michigan court and committed to a state mental hospital. The defendant was never discharged from the hospital, nor was there ever an official declaration that his sanity was restored. The defendant simply escaped from the hospital. While there is ordinarily a presumption that a person is sane, where the accused has been previously adjudged insane, there is a presumption that he is still insane. Horace v. Culver, 111 So. 2d 670 (Fla.1959); Corbin v. State, 129 Fla. 421, 176 So. 435 (1937); State v. Campbell, 123 Fla. 894, 167 So. 805 (1936). The presumption is not conclusive, but continues until the prosecution shows that the defendant’s sanity has been restored, Campbell, supra; however, to do this, the state is not required to establish that the defendant’s sanity was judicially restored. Boone v. State, 183 So. 2d 869 (Fla. 1st DCA), cert. denied, 189 So. 2d 632 (Fla.1966).
This presumption is one which attends all stages of the criminal proceeding. Until the presumption is overcome, the accused may not be tried, convicted, or sentenced. Corbin, supra; Campbell, supra, at 806. Therefore, we must decide whether the presumption was overcome at each stage.
Three weeks before trial, on August 17, 1979, a competency hearing was held before the trial court.1 Testimony was taken from two expert witnesses appointed by the court. Both doctors stated that in their opinion the defendant was competent to stand trial for murder. We find that this testimony was sufficient to overcome the presumption of insanity and hold that the defendant was competent to stand trial.
Similarly, we find that the testimony regarding the defendant’s ability to understand the Miranda warnings was sufficient to overcome the presumption of insanity at the time the confession was given to police. Detective Martinez, who obtained the confession from the defendant testified that he appeared to be acting at full capacity. This testimony was buttressed by the opinion of Dr. Jaslow, a psychiatrist who was called in to interview the defendant the same day. His impression of the defendant, formulated during the two-hour interview, was that despite the prior adjudication of insanity, Eason was able to understand his rights and give a voluntary confession. In the doctor’s judgment, any psychotic process which formerly existed was not actively present on the day Eason confessed to .the murders. Based on this testimony, we find that the state met its burden of overcoming the presumption and must affirm the trial judge’s denial of the motion to suppress.
As to the sanity defense, it has long been held that a defendant’s mental condition at the time of the offense is a question of fact for the jury. Byrd v. State, 297 So. 2d 22, 24 (Fla.1974); Aeree v. State, 153 Fla. 561, 15 So. 2d 262 (1943). While there was conflicting evidence on the issue of insanity, the jury found that the defendant was sane at the time he committed the murders. The record contains sufficient evidence to overcome the presumption of insanity and to support the jury’s verdict.
Finding no merit in the other issues raised by this appeal, we affirm.
. Appellant argues that we must reverse because there is no transcript of the April 14, 1978 competency hearing. While it is true that the record does not contain that transcript, another competency hearing was held on August 17, 1979, for which the transcript is available.
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Thompson v. Crawford, 479 So. 2d 169 (Fla. 3d DCA 1985)…neled; holding that the trial court, although in error, did not exceed its jurisdiction and authority and that jeopardy had attached). “[A] defendant’s mental condition at the time of the offense is a question of fact for the jury.” Eason v. State, 421 So. 2d 35, 37 (Fla. 3d DCA 1982). Where, as here, the defendant has not waived his right to jury trial, the court is without power or authority to decide a fact issue which amounts to a pretrial determination of guilt or innocence. See United States v. Linets…
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Mohumman Iqbal Zabrani v. Riveron, 495 So. 2d 1195 (Fla. 3d DCA 1986)…nt to stand trial. Zabrani contends that, according to the law in Florida, once a person is adjudged to be insane he is presumed to remain insane until it is shown that he has become sane. Horace v. Culver, 111 So. 2d 670 (Fla.1959); Eason v. State, 421 So. 2d 35 (Fla.3d DCA 1982). He argues, therefore, that Monroy must be presumed to have been legally insane, and, thus, legally incompetent, from the time of the murder until the date she was found to be competent. Florida Rule of Civil Procedure 1.510(e) req…
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Johnson v. State, 440 So. 2d 464 (Fla. 1st DCA 1983)…not guilty by reason of insanity, there is a legal presumption that he continues to be incompetent and, thus, cannot be tried and convicted of' the offenses charged until his competency has been restored in a judicial hearing, citing Eason v. State, 421 So. 2d 35 (Fla. 3d DCA 1982), and Alexander v. State, 380 So. 2d 1188 (Fla. 5th DCA 1980). Accordingly, defendant argues, his conviction and sentence must be set aside and the case remanded for a new trial. We disagree for two reasons. In the first place, th…
Previewing 3 of 6 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Acree v. State, 153 Fla. 561 (Fla. 1943)
- Byrd v. State, 297 So. 2d 22 (Fla. 1974)
- Horace v. Culver, 111 So. 2d 670 (Fla. 1959)
- Corbin v. State, 129 Fla. 421 (Fla. 1937)
- State v. Campbell, 123 Fla. 894 (Fla. 1935)
- Boone v. State, 183 So. 2d 869 (Fla. 1st DCA 1966)
- Otis v. Weider, 189 So. 2d 632 (Fla. 1966)
- Bernstein v. Common Mkts., Inc., 189 So. 2d 632 (Fla. 1966)