Also known as: clinical diagnoses · medical diagnosis
Written by attorneys — see sources below.
A determination of a medical condition reached by evaluating the patient's history and physical-examination findings rather than laboratory or imaging studies.
Colin Chambers told the emergency room doctor that his chest pain began immediately after lifting a heavy crate at work and described the exact location and radiation of the discomfort. The physician relied on those details to conclude that Colin had strained an intercostal muscle. The statement was admissible because it was made for and pertinent to the clinical diagnosis.
Christopher Collins presented expert testimony that a clinical diagnosis of schizophrenia supported his claim of inability to form mens rea. The court noted that the diagnosis alone did not establish the legal standard for insanity.
In the early hours of June 21, 2000, Officer Jeffrey Moritz of the Flagstaff Police responded in uniform to complaints that a pickup truck with loud music blaring was circling a residential block. When he located the truck, the officer turned on the emergency lights and siren of his marked patrol car. This prompted petitioner Eric Clark, the truck’s driver (then 17), to pull over. Officer Moritz got out of the patrol car and told Clark to stay where he was. Less than a minute later, Clark shot the officer. The officer died soon after but not before calling the police dispatcher for help. Clark ran away on foot but was arrested later that day with gunpowder residue on his hands. The gun that killed the officer was found nearby, stuffed into a knit cap. Clark was charged with first-degree murder under Ariz. Rev. Stat. Ann. §13–1105(A)(3) for intentionally or knowingly killing a law enforcement officer in the line of duty. In March 2001, Clark was found incompetent to stand trial and was committed to a state hospital for treatment. Two years later the same trial court found his competence restored and ordered him to be tried. Clark waived his right to a jury, and the case was heard by the court. At trial, Clark did not contest that he shot the officer or that the officer died. He relied on his own undisputed paranoid schizophrenia at the time of the incident to deny that he had the specific intent to shoot an officer or knowledge that he was doing so. The prosecutor offered circumstantial evidence that Clark knew the victim was a police officer. The prosecutor also offered testimony indicating that Clark had previously stated he wanted to shoot police and had lured the victim to the scene to kill him. In presenting the defense case, Clark claimed mental illness. He sought to introduce it for two purposes. First, he raised the affirmative defense of insanity. This put the burden on himself to prove by clear and convincing evidence that at the time of the crime he was afflicted with a mental disease or defect of such severity that he did not know the criminal act was wrong. Second, he aimed to rebut the prosecution’s evidence of the requisite mens rea. Ruling that Clark could not rely on evidence bearing on insanity to dispute the mens rea, the trial court cited the Arizona Supreme Court’s decision in State v. Mott. That decision refused to allow psychiatric testimony to negate specific intent. It held that Arizona does not allow evidence of a mental disorder short of insanity to negate the mens rea element of a crime. As to his insanity, Clark presented lay testimony describing his increasingly bizarre behavior over the year before the shooting. This included testimony that Clark thought Flagstaff was populated with aliens trying to kill him and that bullets were the only way to stop them. A psychiatrist testified that Clark was suffering from paranoid schizophrenia with delusions about aliens when he killed the officer. The psychiatrist concluded that Clark was incapable of luring the officer or understanding right from wrong and was thus insane at the time of the killing. In rebuttal, the State’s psychiatrist gave his opinion that Clark’s paranoid schizophrenia did not keep him from appreciating the wrongfulness of his conduct before and after the shooting. The judge then issued a first-degree murder verdict. The judge found that Clark had not established that his schizophrenia distorted his perception of reality so severely that he did not know his actions were wrong. Clark moved to vacate the judgment and life sentence. He argued that Arizona’s insanity test and its Mott rule each violate due process. The trial court denied the motion. Affirming, the Arizona Court of Appeals held that the State’s insanity scheme was consistent with due process. The court read Mott as barring the trial court’s consideration of evidence of Clark’s mental illness and capacity directly on the element of mens rea. The Supreme Court of Arizona denied further review. The United States Supreme Court granted certiorari.
View caseCaleb Chang, an indigent defendant, moved for state-funded psychiatric evaluation after his attorney identified symptoms consistent with a severe mood disorder. The court granted the request so that a clinical diagnosis could be obtained to prepare an adequate defense.
Late in 1979, Glen Burton Ake was arrested and charged with murdering a couple and wounding their two children. He was arraigned in the District Court for Canadian County, Oklahoma, in February 1980. His behavior at arraignment and in other prearraignment incidents at the jail was so bizarre that the trial judge, sua sponte, ordered him to be examined by a psychiatrist for the purpose of advising with the Court as to his impressions of whether the Defendant may need an extended period of mental observation. The examining psychiatrist reported that at times Ake appeared to be frankly delusional and claimed to be the sword of vengeance of the Lord. He diagnosed Ake as a probable paranoid schizophrenic and recommended a prolonged psychiatric evaluation to determine whether Ake was competent to stand trial. In March 1980, Ake was committed to a state hospital to be examined with respect to his present sanity. On April 10, the chief forensic psychiatrist informed the court that Ake was not competent to stand trial. The court held a competency hearing at which a psychiatrist testified that Ake was a psychotic with a diagnosis of paranoid schizophrenia chronic with exacerbation, that he was dangerous, and that he required a maximum security facility. The court found Ake to be a mentally ill person in need of care and treatment and incompetent to stand trial, and ordered him committed to the state mental hospital. Six weeks later, the chief forensic psychiatrist informed the court that Ake had become competent to stand trial while receiving 200 milligrams of Thorazine three times daily. At a pretrial conference in June, Ake's attorney informed the court that his client would raise an insanity defense. Counsel requested that a psychiatrist examine Ake with respect to his mental condition at the time of the offense or that the court provide funds for such an examination. The trial judge denied the motion. Ake was tried for two counts of murder in the first degree and two counts of shooting with intent to kill. At the guilt phase, defense counsel called the psychiatrists who had examined Ake at the state hospital, but none testified about his mental state at the time of the offense. The jury rejected the insanity defense and returned a verdict of guilty on all counts. At the sentencing proceeding, the prosecutor relied on the testimony of the state psychiatrists that Ake was dangerous to society. Ake had no expert witness to rebut this testimony or to introduce evidence in mitigation. The jury sentenced Ake to death on each of the two murder counts and to 500 years' imprisonment on each of the two counts of shooting with intent to kill. On appeal, the Oklahoma Court of Criminal Appeals affirmed the convictions and sentences. The Supreme Court granted certiorari.
View caseClaire Campbell's counsel introduced a clinical diagnosis of psychosis to argue that she lacked rational understanding of the proceedings. The court examined whether the diagnosis sufficiently demonstrated incompetence to stand trial.
In 1992 Scott Louis Panetti broke into the home of his estranged wife's parents in Texas, shot and killed both of them in front of his wife and daughter, and held his wife and daughter hostage overnight before surrendering to police. Tried for capital murder in 1995, Panetti sought to represent himself. A court-ordered psychiatric evaluation revealed a fragmented personality, delusions, and hallucinations, and noted multiple prior hospitalizations for these disorders. He was found competent to stand trial and to waive counsel. At trial he claimed insanity and engaged in bizarre and trance-like behavior before the jury. Less than two months after sentencing the trial court found him incompetent to waive appointment of state habeas counsel. The Texas courts denied relief on direct appeal and state habeas. The federal district court and Fifth Circuit rejected Panetti's first federal habeas petition under 28 U.S.C. § 2254, and this Court denied certiorari. On October 31, 2003 the state trial court set an execution date of February 5, 2004. Panetti then filed his first motion under Texas Code of Criminal Procedure Article 46.05 claiming, for the first time, that mental illness rendered him incompetent to be executed. The trial judge denied the motion without a hearing, and the Texas Court of Criminal Appeals dismissed the appeal for lack of jurisdiction. Panetti filed a second federal habeas petition. The district court stayed execution to permit the state trial court to consider evidence of his current mental state. The state court ordered two mental-health experts to examine Panetti. Their April 28, 2004 report concluded he knew he was to be executed and understood the reason. Without holding a hearing or ruling on Panetti's ten pending motions—including requests for a competency hearing, funds for his own expert, and transcription—the state judge found him competent on May 26, 2004 and closed the case. Panetti returned to federal court. The district court concluded the state proceedings failed to comply with Texas law and were constitutionally inadequate under Ford v. Wainwright. It reviewed the incompetency claim without deference to the state finding but denied relief because Panetti had not shown he met the Fifth Circuit's competency standard. The Fifth Circuit affirmed, and this Court granted certiorari.
View caseCharles Cunningham offered a clinical diagnosis of alcoholism to argue that his public intoxication was involuntary. The court held that the diagnosis did not create a constitutional defense to the criminal charge.
In late December 1966, appellant Leroy Powell was arrested and charged with being found in a state of intoxication in a public place in violation of Texas Penal Code, Art. 477 (1952). He was tried in the Corporation Court of Austin, Texas, found guilty, and fined twenty dollars. He appealed to the County Court at Law No. 1 of Travis County, Texas, where a trial de novo was held. At the county court trial without a jury, the defense presented testimony from psychiatrist Dr. David Wade, who had examined Powell and testified that he is a chronic alcoholic with an uncontrollable compulsion to drink and that he loses the power to control his drinking. Powell testified that he works at a tavern shining shoes, makes about twelve dollars a week which he uses to buy wine, drinks wine every day, gets drunk about once a week, and usually goes to sleep in public places such as the sidewalk when drunk. The arresting officer testified that Powell staggered when he walked, that his speech was slurred, and that he smelled strongly of alcohol. The trial court entered findings of fact that chronic alcoholism is a disease which destroys the afflicted person's will power to resist the constant, excessive consumption of alcohol, that a chronic alcoholic does not appear in public by his own volition but under a compulsion symptomatic of the disease of chronic alcoholism, and that Powell is a chronic alcoholic who is afflicted with the disease. The court nevertheless convicted Powell and fined him fifty dollars. The Texas Court of Criminal Appeals affirmed the conviction. Powell appealed to the United States Supreme Court, which noted probable jurisdiction. The record shows Powell had been convicted of public intoxication approximately one hundred times since 1949 and that he works shining shoes, earns about twelve dollars a week, and uses his earnings to buy wine, getting drunk about once a week usually in public places.
View caseCamila Cervantes presented evidence of a clinical diagnosis of organic brain syndrome to support a diminished-capacity defense. The court considered whether the diagnosis was sufficiently linked to her inability to premeditate.
On the evening of June 4, 1968, five white United States Marine Lieutenants in formal dress uniforms and a woman named Barbara Kelly entered a hamburger shop in Washington, D.C., around 2:40 a.m. after a night out. They ordered food at the take-out counter and noticed three Black men—appellants Alexander and Murdock and Cornelius Frazier—sitting at the other end of the counter. According to prosecution witnesses, a staring contest between Lieutenant Kramer and Alexander led to Alexander tapping Kramer on the shoulder, asking him to step outside, and making a threat. After a racial epithet from Lieutenant King, Alexander drew a .38 caliber revolver. Murdock then reentered and drew his own revolver, after which shots were fired, killing Lieutenants King and Lesnick and wounding Kramer and Kelly. Alexander, Murdock, and Frazier fled in Alexander's car, with Murdock firing additional shots from the window. They were stopped by police within a few blocks, and two revolvers were recovered from the car floorboard. Defense witnesses Frazier and Murdock testified that the Marines were drunk and aggressive, and Murdock claimed he fired in self-defense fearing for his life. At a joint jury trial in February 1969, both were convicted of carrying a dangerous weapon and four counts of assault with a dangerous weapon; Murdock was also convicted of two counts of second-degree murder. Murdock's trial was bifurcated; after the guilt phase, a separate hearing on criminal responsibility was held in November 1969 before the same jury, which found him criminally responsible. Alexander received consecutive sentences totaling five to twenty-three years, and Murdock twenty years to life. Both appealed their convictions to the United States Court of Appeals for the District of Columbia Circuit, which heard argument on December 21, 1970, and issued its decision on April 21, 1972.
View caseA clinical diagnosis rests only on the patient's reported symptoms. A physical diagnosis requires findings from direct examination or testing.
A clinical diagnosis supplies medical information but does not automatically satisfy legal criteria such as the inability to form mens rea or appreciate wrongfulness. Additional evidence tying the diagnosis to the legal test is required.
When the defendant's mental condition is relevant to culpability or punishment, a clinical diagnosis obtained through expert assistance can be essential to mounting an adequate defense.
The diagnosis supplies evidence of the disability, but the court must determine whether the condition meets the legal standard of significantly subaverage intellectual functioning and adaptive deficits that reduce culpability.