Charles Guiteau Trial - Further Readings

Prosecutor
United States
Defendant
Charles J. Guiteau
Crime Charged
Murder.
Chief Prosecutors
George Corkhill, Walter Davidge, John K. Porter, Elihu Root, E. B. Smith
Chief Defense Lawyers
Leigh Robinson, George Scoville
Judge
Walter Cox
Place
Washington, D.C.
Date of Decision
13 January 1882
Decision
Defendant was found guilty and sentenced to death by hanging.
Significance
Guiteau's trial was one of the first murder trials in which the defendant's claim of insanity was subjected to the modern legal test: namely, whether or not Guiteau understood that his actions were wrong.
Less than 20 years after Abraham Lincoln was shot by John Wilkes Booth, the United States would see another president assassinated. James A. Garfield, a Union major general, had a distinguished military career, which he capitalizedon even before the war ended, getting elected to the House of Representatives in 1863. Garfield was a successful politician, becoming the House Republican leader in 1876. Garfield was known for his opposition to President UlyssesS. Grant, a Republican whose scandal-ridden administration and flawed policies had alienated many of his fellow party members such as Garfield. In 1880, Garfield was the Republican candidate for president and won the election.
Unfortunately for Garfield, his presidency had attracted the obsessive interest of one Charles Guiteau. Guiteau claimed to be a lawyer, and specialized intaking small claims court cases for an unheard-of 75 percent contingency fee. Guiteau's legal career never amounted to much, and he was frequently on therun from creditors seeking payment on overdue bills. He also toyed with various political causes, joining the Oneida Community and other experimental religious living communities that were springing up in the 1860s and 1870s. Guiteau tired of the communal life, and moved to Washington, D.C. where he joinedthe Garfield election campaign as a lowly staff member.
Guiteau Takes Revenge on Garfield for an Imaginary Insult
Guiteau never had any position of importance in the Garfield campaign exceptin his own mind. Guiteau's behavior had always been erratic, and it is possible that he contracted venereal diseases that further aggravated his mental problems. He was inspired to write a speech, which he hoped that Garfield woulduse in a debate with the Democratic presidential candidate, W. S. Hancock. Garfield never even read the speech, much less used it in the debate, but Guiteau was convinced that Garfield won the election thanks to his speech. Guiteau demanded to be appointed Ambassador to France, and even personally accostedSecretary of State James G. Blaine several times. Blaine tried to put Guiteau off politely, but eventually lost patience and on their final encounter pushed Guiteau away and told him never to bother him again.
Guiteau was bitter with resentment, and decided to take revenge against Garfield. Guiteau trailed Garfield throughout the month of June of 1881, waiting for the right opportunity. On 2 July, Guiteau got his chance. The Washington newspapers had reported Garfield's plans to go on a trip with his family, andGuiteau waited for the president at the train station he was to leave from. In the station's lobby, Guiteau came from behind Garfield and shot the president in the back. Station police rushed to arrest Guiteau, who offered no resistance. Meanwhile, Garfield was taken away for medical attention.
Guiteau's shot did not immediately kill Garfield. The president survived onlyto be diagnosed as having a fatal wound. The bullet had grazed Garfield's spine and lodged in his stomach, where it came to rest in such a position thatblood continued to circulate, but the bullet could not be removed without killing Garfield. The doctors therefore did not operate, and they could do nothing for Garfield except try to make him comfortable until the inevitable happened. Garfield was a strong man, and he lived for almost three months before he died on 19 September 1881. The American public was outraged by the murder,and one of the soldiers that guarded Guiteau's prison even tried unsuccessfully to shoot him before trial.
Was Guiteau Insane?
Once Garfield was dead, the government could finally try Guiteau for murder.The trial opened on 14 November 1881, in the District of Columbia. The U.S. attorney general, Wayne MacVeagh, determined to secure a conviction, named five lawyers to the prosecution team, including E. B. Smith and George Corkhill,who was also the District of Columbia's district attorney. Corkhill summed up the prosecution's opinion of Guiteau's insanity defense in a pretrial pressstatement that also mirrored public opinion on the issue:

He's no more insane than I am . . . There's nothing of the madman about Guiteau: he's a cool calculating blackguard, a polished ruffian, who has gradually prepared himself to pose in this way before the world . . . he was a dead-beat, pure and simple . . . Finally he got tired of the monotony of dead-beating. Hewanted excitement of some other kind and notoriety, and he's got it.

Unfortunately for his attorneys, Guiteau not only fought their attempt to assert an insanity defense, but insisted on asserting some bizarre legal defenses of his own. For example, he wrote a plea to Judge Cox arguing that the cause of Garfield's death was the doctors' failure to properly treat the bullet wound and therefore Guiteau was not guilty of murder. Of course, Guiteau's argument had no legal support. Any chance of acquitting Guiteau rested with hisattorneys' efforts to prove that he was insane.
There is still some debate over what constitutes legal insanity, but most authorities generally agree that the basic test is whether or not the defendantknew that his or her actions were wrong. At the time of the Guiteau trial, however, the prevailing test of legal insanity was whether or not the defendant knew that his or her actions were criminal. Therefore, even though someone like Guiteau might be considered insane because he or she did not think it was wrong to shoot the president, he or she could be convicted if the judge determined that he or she understood that the law made it illegal to shoot people. By the 1880s, courts were beginning to apply the less harsh "was itwrong" test, which also gave the jury rather than the judge the task of determining insanity.
Influenced by this trend in the law, Judge Cox allowed both sides to argue their case directly to the jury, and intervened only occasionally. Despite strong evidence of his insanity, Guiteau insisted he was sane, so his attorneys simply let him ramble on and hoped that the jury drew the right conclusion. For example, they let Guiteau explain that he shot Garfield not only out of revenge, but also because God had told him that Garfield was ruining the Republican Party and must be killed in order to save the country from the Democrats.Guiteau testified that God had promised to protect him if he shot Garfield:

I want to say right here in reference to protection, that the Deity himself will protect me; that He has used all these soldiers, and these experts, and this honorable court, and these counsel, to serve Him and protectme. That is my theory about protection. The Lord is no fool, and when He hasgot anything to do He uses the best means He can to carry out His purposes.

Judge Cox and the prosecutors agreed that Guiteau's sanity or insanity had tobe measured by whether he knew his actions were wrong, but they were also determined not to let Guiteau escape the hangman. Cox instructed the jury thatany minimal amount of understanding on Guiteau's part would be enough to support a guilty verdict:

When you come . . . to consider . . . sucha crime as we have here, murder most foul and unnatural, the law requires a very slight degree of intelligence indeed.

The way was thus paved for the prosecutors, led by Davidge, to make an emotional appeal to the jurors in their closing argument for Guiteau's conviction:

A man may not have intelligence enough to be made responsible, even for a less crime; but it is hard, it is very hard to conceive of the individual with any degree of intelligence at all, incapable of comprehending thatthe head of a great constitutional republic is not to be shot down like a dog.

The defense was paralyzed, and their efforts to portray Guiteau as not guiltyby reason of insanity were brushed aside. Davidge asserted that Guiteau's erratic behavior could be explained by his overweening ego:

Such isthe indescribable egotism of this man that he put himself on the same planeas the Savior of mankind and the prophets. There you have the explanation ofhis applying for the mission at Paris. For this man, in his indescribable egotism, seems to have thought all along that there was nothing in the world toohigh for him.

On 13 January 1882, the jury rendered its verdict. They found Guiteau guiltyof murdering President Garfield. Guiteau leaped to his feet and screamed at the jurors "you are all low, consummate jackasses." Guards took Guiteau back to his cell, to await execution. On 30 June 1882, Guiteau went to the scaffold, ranting about the "Almighty" and was hanged. Guiteau had been given the benefit of a new and more liberal legal definition of insanity, but like many criminal defendants to come he found out that public opinion influences judgesand juries alike.
Insanity Plea
The insanity defense has been mounted by criminal defendants for several centuries. In fourteenth century England, the insanity plea was available to a person who was "deprived of and memory so as not to know what he [was] doing, no more than an infant, a brute, or a wild beast." England later fashioned theM'Naghten rule, which allowed the insanity defense if the defendant did notknow what she was doing or did not know that what she was doing was wrong.
The M'Naghten rule migrated to the United States, but it has since been modified. Some states made the insanity defense available to defendants who actedunder an "irresistible impulse," allowing for a form of physical insanity tosupplement M'Naghten's recognition of mental insanity. Many states now allowthe insanity defense if the defendant lacked "substantial capacity" to appreciate his or her conduct. On the federal level, the "irresistible impulse" test has been abolished. On the federal level and in some states, defendants onthe federal level must prove their insanity. A few states require the prosecutor to prove the defendant's sanity. A successful claim of insanity does notset a defendant free: insane defendants are sent to secure mental health facilities.
Sources
West's Encyclopedia of American Law, Vol. 6. St. Paul: West Group, 1998.