ADAM JOHNSON, PLAINTIFF IN ERROR,
v.
THE STATE OF FLORIDA, DEFENDANT IN ERROR
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Adam Johnson was convicted of murder in 1908 for a homicide allegedly committed in 1900. The Florida Supreme Court reversed and remanded for a new trial, holding that the trial court erred by admitting an inadmissible certificate regarding Johnson's mental status at the time of discharge from a mental hospital, which was used to rebut evidence of his insanity at the time of the alleged crime.
The court held that the certificate was not legal evidence for the purpose of determining the defendant's insanity at the time the homicide was committed. The statute does not make such certificates evidence for this purpose, and the defendant had no opportunity to cross-examine the persons making the certificate in a judicial proceeding. The court could not say the certificate did not influence the jury, and therefore the defendant was harmed.
“The issue being tried was the insanity of the defendant when the homicide was committed, and even if the certificate had any bearing upon that issue, it was not legal evidence.”
Establishes that the certificate regarding the defendant's mental status at hospital discharge was not admissible to prove insanity at the time of the crime, eight years earlier.
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Join FLexlaw to unlock all legal intelligenceJohnson was convicted in Jackson County Circuit Court in 1908 for murder alleged to have occurred in 1900. Johnson had previously been adjudged insane…
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Whitfield, C. J.
In 1908, the plaintiff in error was convicted in the Circuit Court for Jackson County, for a murder alleged to have been 'committed in 1900. A plea of not guilty was entered at the arraignment, and subsequently the court refused to permit the filing of a plea that the defendant was insane at the time the crime is alleged to have been committed, that the defendant had been adjudged insane under the statute and committed to the hospital for the insane, and that the competency of the defendant to commit the alleged offense had been adjudicated.
The statute authorizing the examination of persons to be committed to the State hospital for the insane, does not contemplate-an inquiry into the responsibility of persons for crimes committed, and an adjudication of insanity preparatory to. commitment to the hospital is not a proper matter for consideration in a trial for a crime. See Reyes v. State, 49 Fla. 17, 38 South. Rep. 257; Davis v. State, 44 Fla. 32, 32 South. Rep. 822.
The issue of insanity at the time of the alleged commission of an offense may be tried under a plea of not guilty, and as this was done in this case, there was no error in refusing to allow the plea to be filed, even if the plea was not improper in seeking in some of its averments to raise an immaterial issue.
A formal plea that a defendant is insane when placed upon trial is not necessary. If upon observation or suggestion, it appears to the court that a quetsion as to the defendant’s sanity exists, such issue may be determined by the court as may be deemed best under the law, and the trial awaits the determination of the issue. If the defendant is found to be insane, the trial will be postponed. 22 Cyc. 1213; Stewart v. State, 124 Wis. 623, 102 N. E. Rep. 1079; 4 A. & E. Ann. Cas. 389 and note; Williams v. State, 45 Fla. 128, 34 South. Rep. 279.
All persons are presumed to be sane; and when insanity at the time of committing an alleged offense is relied on as a defense, and the evidence for the State does not raise a reasonable doubt as to the sanity of the defendant when the offense was committed, it is incumbent upon the defendant to submit evidence sufficient to raise a reasonable doubt of his guilt. If such doubt is raised by the evidence, the defendant should be acquitted. Armstrong v. State, 30 Fla. 170, 11 South. Rep. 618, 17 L. R. A. 484. In such cases the verdict should state the ground of acquittal and the court should make appropriate orders under the statute; Sec. 3992 General Statutes.
To rebut the defendant’s evidence as to his insanity at the time of the alleged homicide, the court admitted in evidence over the objection of the defendant, a certificate of the Superintendent and physician at the State hospital for the insane to the effect that the defendant was on July 25th, 1908, “discharged from the hospital by order of the examining board, he not being insane.”
The issue being tried was the insanity of the defendant when the homicide was committed, and even if the certificate had any bearing upon that issue, it was not legal evidence.
The statute does not make the certificate evidence for such purpose and it does not appear that the defendant had been given in a judicial proceeding an opportunity to cross examine the persons making the certificate. See Putnal v. State, 56 Fla. 86, 47 South. Rep. 864.
It cannot be said that the certificate did not influence the jury in determining whether a reasonable doubt had been raised as to the defendant’s guilt, and that the defendant was not harmed.
The judgment is reversed and the cause is remanded for a new trial.
All concur, except Barkhill, J., absent on account of illness.
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Citator
Cited By (15 total)
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Southworth v. State, 98 Fla. 1184 (Fla. 1929)…sal to impanel a jury to inquire into defendant’s present sanity were assigned as error. A plea that defendant is insane when brought to trial is not necessary, as such issue may be determined without a formal plea to that effect. Johnson v. State, 57 Fla. 18, 49 So. R. 40. The trial court, in the order in the case, denying a new trial, explained further its ruling as to sanity of defendant at the time of trial as follows: ‘ ‘ There was nothing before me to suggest the insanity of the defendant, except…1 / 2
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State ex rel. George J. Deeb v. Fabisinski, 111 Fla. 454 (Fla. 1933)…The method of settling the question is within the discretion of the trial court. 14 R. G. L. 606. See also note III, 38 L. R. A. 579; 16 C. J. 789. A formal plea that' a defendant is insane when placed upon trial is not necessary. Johnson v. State, 57 Fla. 18, 49 South. Rep. 40; Williams v. State, 45 Fla. 128, 34 South. Rep. 279. Now the probate or chancery court has no criminal jurisdiction, and a lunacy or insanity proceeding is not in its nature a criminal proceeding but rather civil in character, an…
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Parkin v. State, 238 So. 2d 817 (Fla. 1970)….L.P., Criminal Law, § 30. In the absence of statute the issue of insanity at the time of the alleged commission of an offense could be tried under a plea of not guilty. A formal plea that a defendant was insane was not necessary. Johnson v. State, 57 Fla. 18, 49 So. 40 (1909). The Criminal Procedure Act of 1939 included Fla.Stat. § 909.17, F.S.A., setting out the procedure for interposing a plea of not guilty by reason of insanity whereby the defendant is required to give notice of such defense at arra…
Previewing 3 of 15 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Davis v. State, 44 Fla. 32 (Fla. 1902)
- Armstrong v. State, 30 Fla. 170 (Fla. 1892)
- Putnal v. State, 56 Fla. 86 (Fla. 1908)
- Williams v. State, 45 Fla. 128 (Fla. 1903)
- Reyes v. State, 49 Fla. 17 (Fla. 1905)