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Insanity Defense - Defendants' Rights

riggins court mellaril trial

When PLEADING insanity, a defendant might not want to present the best possible image at trial. In Riggins v. Nevada, 504 U.S. 127, 112 S. Ct. 1810, 118 L. Ed. 2d 479 (1992), defendant David Riggins was charged with robbing and murdering Las Vegas resident Paul Wade. After being taken into custody, Riggins complained that he was hearing voices in his head and that he was having trouble sleeping. A psychiatrist at the jail prescribed 100 milligrams per day of Mellaril, an antipsychotic drug. By the time of trial, the psychiatrist was prescribing 800 milligrams per day of Mellaril.

Just before trial, Riggins's attorney moved the court to suspend administration of the Mellaril. Riggins was pleading not guilty by reason of insanity, and his attorney wanted the jury to see Riggins in his natural state. According to one psychiatrist, Dr. Jack Jurasky, Riggins "would most likely regress to a manifest psychosis and become extremely difficult to manage" if he were taken off Mellaril.

The court denied the motion, and Riggins was convicted and sentenced to death. The Nevada Supreme Court affirmed Riggins's convictions and death sentence. On appeal to the U.S. Supreme Court, the convictions were reversed. According to the high court, Nevada had violated Riggins's due process rights under the Sixth and Fourteenth Amendments. In the absence of evidence that the treatment was medically appropriate and essential for Riggins's own safety or the safety of others, and without an exploration of less intrusive alternatives, the trial court had erred by denying Riggins's liberty interest in freedom from antipsychotic drugs.

According to the Court, the administration of the Mellaril jeopardized a number of Riggins's trial rights. Not only was it possible that the Mellaril had affected Riggins's outward appearance, and thus his defense, but the high daily dosage of Mellaril also might have affected Riggins's testimony, his ability to communicate with his attorney, and his ability to follow the proceedings. Although the defense had been allowed to present expert testimony on the nature of Riggins's mental condition, the Court concluded that the compromise of Riggins's trial rights was reversible error.

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