Patton v. State
| Docket Number: | 2010-KA-00423-COA Linked Case(s): 2010-KA-00423-COA ; 2010-CT-00423-SCT |
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| Court of Appeals: |
Opinion Link Opinion Date: 08-16-2011 Opinion Author: Maxwell, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Murder - Insanity defense - M’Naghten test - Weight of evidence Judge(s) Concurring: Lee, C.J., Irving and Griffis, P.JJ., Myers, Barnes, Ishee, Roberts, Carlton and Russell, JJ. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 11-10-2009 Appealed from: Jackson County Circuit Court Judge: Robert P. Krebs Disposition: CONVICTED OF MURDER AND SENTENCED TO LIFE IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS District Attorney: Anthony N. Lawrence, III Case Number: 2008-10,847(1) |
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| Party Name: | Attorney Name: | |||
| Appellant: | Frank Demetrius Patton |
LESLIE S. LEE, BENJAMIN ALLEN SUBER |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: LADONNA C. HOLLAND, SCOTT STUART |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Murder - Insanity defense - M’Naghten test - Weight of evidence |
| Summary of the Facts: | Frank Patton was convicted of murder and sentenced to life. He appeals. |
| Summary of Opinion Analysis: | Patton argues that the jury’s rejection of his insanity defense is against the overwhelming weight of the evidence. Mississippi follows the M’Naghten test to determine a criminal defendant’s sanity. Under the test, it must be clearly proved that at the time of committing of the act the accused was laboring under such defect of reason from disease of the mind as not to know the nature and quality of the act he was doing, or if he did know it, that he did not know that what he was doing was wrong. In making its determination on the defendant’s sanity, the jury may accept or reject expert and lay testimony. When there is conflicting testimony on the issue of the defendant’s sanity, a jury’s verdict on that issue is essentially conclusive and unreviewable. In this case, there was conflicting expert testimony. It was the jury’s responsibility to resolve this conflict. Further, the jury was free to draw inferences from the circumstances surrounding the killing. Patton’s inconsistent statements to the police detective could have been viewed quite negatively by the jury. The alleged marital difficulties and his wife’s mention of divorce in the days leading to the shooting tend to show a possible motive for the shooting. And the physical and medical evidence strongly supports the State’s theory that Patton shot his wife, then intentionally shot himself as some sort of a ruse or effort to conceal his crime. Thus, the State presented ample evidence to establish Patton’s sanity at the time of the shooting. |
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