People v. McBride

California Court of Appeal Dec 1, 1933 No. Docket No. 2349.Published

Before: Houser

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Holding. The court held that a defendant is legally responsible for criminal acts if they possess the reasoning capacity to distinguish right from wrong, even if they suffer from partial insanity or delusions. Furthermore, the court affirmed that the burden of proving insanity by a preponderance of the evidence rests on the defendant, as the law presumes sanity.

Issues

Whether the evidence was sufficient to support the jury's finding that the defendant was sane at the time of the offenses.
Whether the burden of proving sanity rests upon the prosecution or the defendant.
Whether the trial court's evidentiary rulings constituted prejudicial error requiring reversal.

Disposition. affirmed

HOUSER, J.

Defendant appeals to this court from three judgments which followed his conviction on each of three accusations of the crime of robbery, as well as from a judgment by which he was found to have been sane at the time when each of said crimes was committed; also from three orders by which his motion for a new trial with respect to each of said judgments was denied.

The principal point presented by appellant as a sufficient reason for a reversal of said judgments is that “the verdicts of the jury finding defendant and appellant sane, are erroneous and not sustained by the evidence”.

Without herein setting forth a detailed statement of the evidence adduced on the trial of the action, it may suffice to state that from an examination of the record herein it would seem clear that by a preponderance of the evidence, on the dates represented by the occasions when each of the several crimes of which defendant is accused was committed, apparently he was insane with respect to one or more facts, or situations either then present, or which ■were suggested to defendant for his consideration. But with reference to the pertinent question of his insanity in the manner, or to the degree, that it would legally absolve him from responsibility for the commission by him of criminal acts, and in particular for the crime or crimes of which he was charged by the information, the evidence, which was substantial in its nature, was equally preponderating to the effect that at the time when each of the offenses was committed, defendant was possessed of reasoning capacity sufficient for him to clearly distinguish between right and w^rong, had consciousness that what he was then doing was criminal in its nature, and fully appreciated the fact that if he were pursued to conviction therefor, punishment would result.

In the case of

People

Willard,

150 Cal. 543, 554 [89 Pac. 124, 129], a general rule, which ever since its pro

[524]

nouncement has been consistently followed by the courts of this state, and which it is thought governs the situation here presented, was announced as follows:

People v. McBride

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HOUSER, J.

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