Hawthorne v. State


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Docket Number: 2002-CT-01142-SCT
Linked Case(s): 2002-CT-01142-SCT ; 2002-CT-01142-SCT ; 2002-CT-01142-SCT ; 2002-KA-01142-COA ; 2002-KA-01142-COA

Supreme Court: Opinion Link
Opinion Date: 09-16-2004
Opinion Author: Smith, C.J.
Holding: Reversed and Remanded

Additional Case Information: Topic: Manslaughter - Weight of evidence - Insanity - M’Naghten test
Judge(s) Concurring: Waller and Cobb, P.JJ., Carlson, Dickinson and Randolph, JJ.
Non Participating Judge(s): Diaz and Graves, JJ.
Concur in Part, Dissent in Part 1: Easley, J., Concurs in Part and Dissents in Part Without Separate Written Opinion
Procedural History: Jury Trial
Nature of the Case: CRIMINAL - FELONY
Writ of Certiorari: Granted
Appealed from Court of Appeals

Trial Court: Date of Trial Judgment: 07-01-2002
Appealed from: Lee County Circuit Court
Judge: Richard Bowen
Disposition: Convicted of manslaughter.
District Attorney: John Richard Young
Case Number: CR01-176

Note: The supreme court reversed the court of appeals as to it rendering the trial court and it remanded the case for a new trial.

  Party Name: Attorney Name:  
Appellant: Curtis David Hawthorne




ROBERT W. DAVIS CHRISTI R. McCOY



 

Appellee: State of Mississippi OFFICE OF THE ATTORNEY GENERAL BY: BILLY L. GORE  

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Topic: Manslaughter - Weight of evidence - Insanity - M’Naghten test

Summary of the Facts: Curtis Hawthorne was convicted of manslaughter after he caused a motor vehicle wreck which killed another person. Hawthorne claimed that he was insane at the time of the wreck. Hawthorne was sentenced to fifteen years with seven years suspended. Hawthorne appealed, and the Court of Appeals reversed and rendered. The Supreme Court granted certiorari.

Summary of Opinion Analysis: The question of whether a defendant in a criminal case was insane at the time of the offense is controlled by the M’Naghten test. Under the M’Naghten test, it must be proved that at the time of committing the act that 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. The determination as to a defendant’s sanity is a question to be resolved by the jury, which may accept or reject expert and lay testimony. The Court of Appeals found that the State failed to produce sufficient evidence, or any evidence at all, to prove Hawthorne’s sanity beyond a reasonable doubt. However, there is evidence from which jurors could determine that Hawthorne was aware his actions were wrong. During the State’s case-in-chief, the evidence indicated that Hawthorne was avoiding many other barriers and had been driving for miles through town before causing this wreck. It was also shown through eyewitness testimony that after the wreck, Hawthorne left his truck, looked around and then ran from the scene. This lay witness testimony was probative of whether Hawthorne knew right from wrong and sufficient evidence to allow the trial court to deny Hawthorne’s motion for directed verdict. The defense put forth evidence showing Hawthorne’s behavior days before this wreck. According to the defense, Hawthorne ran from the scene because he was still under the delusion that he had to get back to Virginia to cure his wife, deliver the cross to his daughter, and be home when the world ended. The police officer who ran after Hawthorne testified that Hawthorne was sweating profusely and was mumbling. Hawthorne’s behavior was so erratic that the police believed Hawthorne was on drugs. This erratic behavior continued throughout the questioning. The defense produced four medical experts who testified that Hawthorne was unable to appreciate the difference between right and wrong. The record lacks substantial credible evidence suggesting that at the time in question, Hawthorne was sane in the M’Naghten sense. Even though sanity is for the jury to determine, the State must produce substantial evidence regarding the defendant’s sanity. If the verdict is against the overwhelming weight of the evidence, a new trial should be ordered. The jury verdict was against the overwhelming weight of the evidence on the issue of Hawthorne’s sanity. Therefore, Hawthorne must be retried.


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