Hughes v. Mathews

1978

Venue: 7th Cir

Facts: Hughes killed his wife and neighbor one night in the midst of an ugly divorce. Prior to the trial, court-appointed psychiatrists apparently find him not insane.

Posture: Because of the findings by the court-appointed psychiatrists, he withdrew his mental disease or defect plea. Motion to introduce psychiatrict testimony regarding the capacity to form specific intent (element of 1st degree murder) is denied. Convicted. Appeal.

Issue: Three of them:
  1. Was this evidence relevant?
  2. Was it competent?
  3. Were the reasons for excluding it arbitrary?

Holding: Yes, yes, yes.

Rule: Your right to present evidence is violated if the state recognizes its relevance and competence, but denies its use arbitrarily.

Reasoning: Degree of intent is relevant, and psychiatric testmony is comptetent (because, look, the court appoints psychiatrists!). This doesn't violate the integrity of the bifurcated trial system, because there was no bifurcated trial (the not-guilty plea was withdrawn). And this is just about one element of the crime, not muddying the water.

Dicta: We're not interfering with WI standards for responsibility, and we're not constitutionalizing the right to present psychiatric testimony. All we're saying is that this was an arbitrary suppression of relevant and competent evidence, and the state didn't have a good enough reason.