Case Caption: Bruce K. Farrell vs. People of the Virgin IslandsCase Number: S.Ct.Crim. No.: 2010-0041Date: 03/03/2011Author: Hodge, Rhys S. Citation: Summary:

The Supreme Court holds that the insanity defense is available in both jury and bench trials. However, because the right to raise the insanity defense is personal to the defendant, the Superior Court may not sua sponte impose that defense unless it first finds that the evidence adduced in the proceedings raises a sufficient question as to the defendant's mental responsibility at the time of the crime, and then conducts an inquiry into (1) whether the defendant is presently competent to stand trial; (2) if so, whether based on present mental capacity, the defendant could intelligently and voluntarily waive the insanity defense, and whether he actually has done so; and, if not, (3) whether the evidence of the defendant's mental condition at the time of the alleged crime required imposition of the insanity defense. Additionally, the Supreme Court holds that the Superior Court may only take judicial notice of a fact if it represents general knowledge that cannot be reasonably questioned or disputed, and thus, while it can take judicial notice of the existence of a document, it cannot take judicial notice that the contents of that document are true. Thus, the Supreme Court concludes that the Superior Court committed plain error when it sua sponte imposed the insanity defense on a defendant after taking judicial notice of a psychiatrist's report. The Supreme Court, however, holds that, because the defendant was tried in a bench trial, the proper remedy for the Superior Court's error is not a new trial, but a new judgment based on the admissible evidence presented at the bench trial.

Attachment: Open Document or Opinion