Steele v. Wisconsin

1980

Court: Wisconsin Supreme Court

Facts: Steele killed his wife. No other facts are recited.

Posture: Convicted at trial. Appeal on the grounds that excluding expert testimony about capacity to form intent, in the guilt phase of the bifurcated trial, was error. Court of Appeals affirms, and appeal goes to Supreme Court.

Issue: Can defendants present psychiatric testimony about capacity to form intent in the guilt phase of a bifurcated trial?

Holding: Affirmed, overruling part of Schimmel.

Rule: Evidence about intent is admissible in the guilt phase, but not psychiatric evidence. That goes in the mental responsibility phase.

Reasoning: Doing otherwise undermines the whole point of a bifurcated trial, exposes the jury to duplicate testimony, and introduce confusion about matters of expert opinion, when we should be trying to establish facts.

Dicta: