Hawthorne v. State
| Docket Number: | 2002-KA-01142-COA Linked Case(s): 2002-CT-01142-SCT ; 2002-CT-01142-SCT ; 2002-CT-01142-SCT ; 2002-CT-01142-SCT ; 2002-KA-01142-COA |
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| Court of Appeals: |
Opinion Link Opinion Date: 10-21-2003 Opinion Author: Lee, J. Holding: Reversed and Rendered |
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| Additional Case Information: |
Topic: Manslaughter by culpable negligence - Sufficiency of evidence - Sanity burden of proof Judge(s) Concurring: King, P.J., Bridges, Irving and Chandler, JJ. Non Participating Judge(s): Griffis, J. Dissenting Author : Southwick, P.J. Dissent Joined By : McMillin, C.J., Thomas and Myers, JJ. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
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| Trial Court: |
Date of Trial Judgment: 07-01-2002 Appealed from: Lee County Circuit Court Judge: Richard Bowen Disposition: CONVICTED OF MANSLAUGHTER BY CULPABLE NEGLIGENCE AND SENTENCE OF FIFTEEN YEARS IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS WITH SEVEN YEARS SUSPENDED. District Attorney: John Richard Young Case Number: CR01-176 |
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| Party Name: | Attorney Name: | |||
| Appellant: | Curtis David Hawthorne |
ROBERT W. DAVIS
CHRISTI R. MCCOY |
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| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL BY: BILLY L. GORE |
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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: | Manslaughter by culpable negligence - Sufficiency of evidence - Sanity burden of proof |
| Summary of the Facts: | Curtis Hawthorne was convicted of manslaughter by culpable negligence. He was sentenced to fifteen years with seven years suspended. He appeals. |
| Summary of Opinion Analysis: | Hawthorne argues that the State did not meet its burden of proof in establishing sanity beyond a reasonable doubt. Under the M'Naghten test for determining a person's sanity at the time of the crime, it must be proved that at the time of committing 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. Once the accused meets his initial burden of introducing evidence creating a reasonable doubt as to his sanity at the time of the act, it becomes the burden of the State to present sufficient evidence to prove the accused's sanity beyond a reasonable doubt. The record in this case shows that a reasonable doubt was created as to Hawthorne's sanity at the time of the accident as established by testimony from three physicians who were experts in psychiatry and who had seen Hawthorne at some point after the accident. The State was then required to prove the accused’s sanity beyond a reasonable doubt. However, the State failed to present any evidence at all to prove Hawthorne's sanity beyond a reasonable doubt. Therefore, the verdict is reversed and rendered. |
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