On April 23, 2000, Darren Paul Odell attended Easter dinner at his great aunt’s house, where he fired three bullets into his father, Dennis Raymond Odell, resulting in his death. The appellant was charged with first-degree murder under Minn. Stat. & 609.185(a) (1) (2001). The appellant pleaded not guilty by reason of mental illness under Minn. Stat. &611.026 (2002), testifying that he did not it was morally wrong to kill his father. Mental evaluations were assigned by the court to examine the mental state of the appellant at the time of the crime. After an initial set of mental evaluations, new evidence appeared, in which the sister of the appellant found his post-it notes while cleaning the house. The review of these notes led to a second updated medical examination of the appellant.
Issue
Should Minnesota consider that Darren Paul Odell is qualified under Minn. Stat. &611.026 (2002), also referred to as the M’Naghten rule, to be excused for criminal liability due to not knowing the nature of the act, or that it was wrong.
No. The court found that sufficient evidence exists to support the guilt of the appellant, who failed to provide evidence that his mental illness at the time of the crime prevented him from knowing that the act was wrong. The court affirmed the conviction of the appellant in favor of the state.
The main element in the M’Naghten rule is not whether the person had a mental illness at the time of committing the crime or not, but rather whether because of such illness he did not understand the nature of the act. In that regard, all parties appointed to examine the mental state of the appellant at the time of committing the crime agreed that he suffered from a mental illness. Accordingly, after the first examination the parties agreed that his illness did not prevent the appellant for understanding the nature of the committed act. After the updated medical review, due to the occurrence of new evidences, the opinion of the experts diverged. Answering the question whether such mental illness was the reason for not knowing the nature of the act or that it was wrong, the opinions divided between the experts. The court weighted the opinion of experts that were consistent with the facts of the case, specifically the fact that the appellant was able to normally communicate before and after the murder. The reasoning was that the issue of legal illness is for the fact-finder to resolve and to determine the appropriate weight of the evidences. In that regard, the court disregarded the opinions of the experts that changed their opinions, as the new evidences were irrelevant to the mental state of the appellant at the time of the crime.
Rule: In determining the weight of the evidence, the court disbelieved contradictory evidences. The court reached the conclusion that evidences support a finding of guilt of the appellant, and his competency to proceed to trial. The decision was ruled en banc.