Richard Anthony Arriola was found guilty of first degree murder, attempted first degree murder, and two counts of attempted second degree murder after a bench trial. The trial court sentenced him to life imprisonment plus fifteen years. Following an appeal, the court identified that the trial court had applied an improper legal standard regarding the insanity defense and remanded the case for a new trial. The facts indicate that Arriola, initially a well-adjusted youth, exhibited signs of mental illness during college, leading to reclusiveness and paranoia. His erratic behavior included extensive travel, brief military service, and unusual preaching activities. He had a history of mental health treatment, being diagnosed with paranoid schizophrenia, but did not adhere to follow-up care post-hospitalization. The court’s decision emphasized the need for a correct assessment of the insanity defense during retrial.
Upon his release from a previous hospitalization, the Defendant refused to take his medication and moved into his parents' basement, which he kept cluttered. In 1991, he was hospitalized again due to a judicial order after a physical altercation with his brother over hygiene issues. He was treated for paranoid schizophrenia for thirty days but ceased treatment upon release, leading to neglect of personal hygiene. By September 1995, the Defendant began posting signs for various businesses he believed he operated. When police served an eviction warrant to remove the signs, the Defendant threatened them with his neighbor’s dogs. Following his parents' removal of the signs, the Defendant replaced them and resisted further removal efforts.
On September 22, 1995, Officers Johnnie Spears and Jerry Newsome attempted to serve the eviction warrant. Upon their arrival, the Defendant emerged in an agitated state and shot Officer Spears in the mid-section, causing him to fall. Officer Newsome also collapsed after being shot. The Defendant initially used a handgun and then switched to a shotgun while retreating to his police cruiser. Officer Spears made a distress call, and Officer Mike Hagar, who arrived later, found Officer Newsome unresponsive. Following this, additional police and a SWAT team were called to the scene. John Arriola, the Defendant’s brother, informed the police of the Defendant's schizophrenia. The SWAT team attempted negotiation but received no response. After deploying distraction devices, they encountered gunfire from the Defendant before entering the house.
Officer Randy Hickman reported that during a SWAT operation, the Defendant fired four shots at the team—two shots after the deployment of devices and two more after commands to come out were issued. As the SWAT team deliberated on their next steps, the Defendant emerged from the house, cursing. A SWAT member subdued him by kicking him, leading to an attempt by the Defendant to grab an officer's weapon, although he only got hold of the strap. Following his arrest, he was transported to the hospital by Officer Pat Postiglione, who noted the Defendant was subdued and refused to provide a statement due to distrust of the government. Officer Larry Flair described the Defendant as coherent and conscious, but he chose not to waive his Miranda rights or consent to a search of his property.
A search of the basement where the Defendant was found revealed a disarrayed area with a handgun hidden in the drywall. Medical examiner Dr. Bruce Levy testified that Officer Jerry Newsome was shot five times, three of which were immediately fatal. Since his arrest, the Defendant has been housed at MTMHI, receiving treatment for paranoid schizophrenia. His delusions included beliefs about his origins, a need to baptize family members, and grandiose thoughts of owning the government and the world bank. Dr. Rokeya Farooque, his doctor, stated that the Defendant was psychotic on the day of the shooting and unable to appreciate the wrongfulness of his actions, feeling justified in defending himself due to his delusions. Dr. Samuel Craddock also assessed the Defendant, noting his deep suspicion of others and inability to comprehend the situation during the incident. When questioned about the shooting, the Defendant expressed complaints of burning sensations and implied he did not recognize the illegality of his actions. Dr. Patricia Corry mentioned that the Defendant had two plans related to his mental illness.
Plan A encompassed the Defendant's delusional beliefs, including aspirations of becoming King Richard. Plan B involved memories related to a 1995 shooting, during which the Defendant experienced intrusive thoughts and auditory hallucinations urging violence. He claimed to hear voices telling him to shoot anyone who wronged him and believed he was on a journey to the Vatican with a fictional character, Vanessa Corona, whom he thought was the District Attorney of Miami. The Defendant also expressed intentions to conquer eighty-five countries and viewed himself as a saint or preacher. He feared a virus he believed could transfer from computers to humans, particularly when police visited him.
The Defendant was in custody from 1995 until 2006, when he was deemed competent for trial, although his treatment progress was slow due to challenges in finding the right medication. Ultimately, the trial court convicted him of first-degree murder, attempted first-degree murder, and two counts of attempted second-degree murder, sentencing him to life imprisonment plus fifteen years.
On appeal, the Defendant argued that the trial court improperly applied the legal standard for the insanity defense, asserting that he was unfairly required to demonstrate he was unable to appreciate both the nature and the wrongfulness of his actions. He also contended that the evidence supported an insanity defense. The State countered that the trial court's interpretation of the legal standard was appropriate and that it considered the specifics of the case to assess the Defendant's understanding of the wrongfulness of his actions. The appellate court remanded the case for clarification of the trial court's findings while affirming the sentences.
To successfully establish an insanity defense under Tennessee law, a defendant must demonstrate, due to a severe mental disease or defect, that he either did not understand the nature of his actions or did not recognize their wrongfulness. This is outlined in Tennessee Code Annotated section 39-11-501, which allows for an affirmative defense if the defendant can prove this by clear and convincing evidence.
The interpretation of statutory language follows its natural and ordinary meanings unless specified otherwise by the legislature. In this context, the term "or" is understood as a disjunctive, indicating that the defendant need only prove one of the two conditions to succeed with the insanity defense.
In a previous case, Arriola I, the court remanded the case for clarification regarding the defendant's insanity defense. The trial court concluded that the ability to appreciate the wrongfulness of an act is a narrower aspect of understanding the nature of the act. Although expert testimony indicated that the defendant could not appreciate the wrongfulness of his actions, it did not confirm that he lacked understanding of the nature of his actions. The court reasoned that since the defendant failed to prove he could not appreciate the nature of his actions, he could not claim he was unaware of their wrongfulness.
The trial court identified specific facts suggesting the defendant's awareness of wrongfulness, such as hiding his weapon when approached by deputies, shooting and injuring one deputy while killing another, and subsequently barricading himself, indicating knowledge of the wrongfulness of his actions.
The defendant's actions were deemed wrongful, as evidenced by his attempt to hide his pistol and his refusal to discuss the incident with law enforcement or treatment providers, suggesting an awareness of wrongdoing. The trial court found that the defendant did not meet the burden of clear and convincing evidence to prove he was unable to appreciate the nature or wrongfulness of his actions. However, the court misapplied the legal standard for the insanity defense, conflating the concepts of "wrongfulness" and "nature." Wrongfulness pertains to a defendant's moral understanding of their actions, while nature addresses their cognitive understanding. The Arizona insanity defense statute, which parallels Tennessee's, differentiates between these two elements. The trial court incorrectly concluded that failing to prove an inability to appreciate the nature of the actions also precluded proving inability to appreciate their wrongfulness. A defendant only needs to demonstrate, due to a severe mental disease or defect, that he could not appreciate either the nature or the wrongfulness of his actions. This aligns with the M'Naghten standard, which requires proof of knowledge regarding both the nature of the act and its moral wrongfulness. Failure to apply both prongs of this test restricts the insanity defense, as demonstrating either inability is sufficient to satisfy the burden of proof.
The Tennessee insanity defense consists of two prongs: whether the defendant understood the nature of his actions or the wrongfulness of his actions, with success requiring proof of only one prong. The trial court applied an incorrect legal standard regarding this defense, which constitutes an error affecting the verdict and the fairness of the trial. Although the Defendant asserted he proved by clear and convincing evidence his inability to appreciate the wrongfulness of his conduct due to a severe mental disease, the court determined that the trial court's factual findings, when viewed favorably to the State, did not support the insanity defense sufficiently. Consequently, the case must be remanded for a new trial, with a different trial judge assigned, as the erroneous standard negated the Defendant's right to a fair trial. The appellate court reversed the trial court's judgments and mandated a reassignment within the Davidson County Criminal Court.
