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 conducted by the Criminal Court for Davidson County, resulting in an effective sentence of life imprisonment plus fifteen years. On appeal, Arriola argued that the trial court incorrectly applied the legal standard for his insanity defense, requiring him to prove both an inability to appreciate the nature of his acts and an inability to appreciate their wrongfulness. Additionally, he contested the imposition of consecutive sentences. The appellate court remanded the case for clarification of the trial court's factual findings regarding the insanity defense. The case stemmed from a standoff with law enforcement on September 22, 1995, leading to the death of Officer Jerry Newsome. Evidence presented during the trial indicated that Arriola had a history of mental illness, including diagnoses of paranoid schizophrenia, which began during his college years and continued despite multiple hospitalizations. His behavior included reclusiveness, paranoia, and peculiar activities, such as preaching and attempting to baptize family members, which indicated a decline in his mental health.
In 1989 or 1990, the Defendant moved into the basement of his parents' house, which was described as cluttered. He was hospitalized for the third time in 1991 due to a judicial order following a fistfight with his brother, John, over the Defendant's hygiene. John agreed to withdraw charges if the Defendant entered an inpatient treatment facility, where he was treated for paranoid schizophrenia for thirty days before being released. After his release, the Defendant discontinued treatment and neglected personal hygiene, growing a beard and unkempt hair.
In September 1995, the Defendant began posting signs for various businesses he believed he operated, leading to police involvement when his parents received a warrant demanding the signs be removed or face fines. The Defendant threatened police with his neighbor's dogs, and despite his parents' compliance, he replaced the signs. They considered serving him an eviction warrant to compel treatment, similar to the prior incident in 1991.
On September 22, 1995, Officers Johnnie Spears and Jerry Newsome attempted to serve the eviction warrant. The Defendant, appearing aggressive and cursing, shot Officer Spears in the midsection and also shot Officer Newsome. Spears observed the Defendant switching from a handgun to a shotgun while attempting to call for help. Officer Mike Hagar responded to the scene and confirmed Officer Newsome was unresponsive, leading to the deployment of a SWAT team after it was established the Defendant remained in the basement.
The SWAT team attempted negotiation but received no response. When they entered the house, the Defendant opened fire after distraction devices (stun grenades) were deployed. Officer Randy Hickman reported that the Defendant fired several shots at the team, leading to a tense standoff until the Defendant eventually exited the house.
Officer Hyde reported that the basement encountered by law enforcement was heavily filled with smoke, and as the Defendant emerged while cursing, a SWAT team member subdued him by kicking him to the ground. The Defendant attempted to seize an officer's weapon but only grasped the strap. He was subsequently arrested and transported to a hospital for injury evaluation, accompanied 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 observed the Defendant as coherent and conscious; however, the Defendant did not waive his Miranda rights and denied consent for a property search.
The basement was described as disorganized by Officer Bill Pridemore, who discovered a handgun hidden in the drywall. Medical examiner Dr. Bruce Levy testified that Officer Jerry Newsome had been shot five times, with three shots being immediately fatal. Following his arrest, the Defendant was placed in MTMHI for treatment of paranoid schizophrenia and exhibited delusions, including beliefs about his birth and a need to baptize family members. Dr. Rokeya Farooque, his treating physician, stated that the Defendant believed he was destined to be Pope and claimed ownership of significant entities, including the U.S. government.
Dr. Farooque confirmed a diagnosis of paranoid schizophrenia in 1996, highlighting symptoms such as bizarre behavior and delusional thinking. She noted that on September 22, 1995, the Defendant was psychotic and unable to recognize the wrongfulness of his actions, feeling justified in his behaviors. Dr. Samuel Craddock, another treating physician, echoed this assessment, indicating that the Defendant was highly suspicious and believed he owned locations like Palm Beach, Florida. He expressed doubts about the Defendant's ability to comprehend events during the shooting, suggesting he was too mentally ill to engage emotionally. The Defendant reported sensations of burning when discussing the incident and implied ignorance of the legality of shooting at police. Dr. Patricia Corry identified two delusional plans in the Defendant's mental state: one involving grandiose fantasies and the other related to memories of the shooting, which he recalled through intrusive thoughts and sensations.
The Defendant reported to Dr. Corry that he experienced auditory hallucinations instructing him to harm others. He believed the ship Queen Mary II was transporting him and a fictional character he created, Vanessa Corona, to the Vatican. The Defendant perceived Corona as the District Attorney in Miami and thought she would accompany him when he assumed roles such as King Richard, President, or the first American Jewish Pope. During treatment, he outlined plans to conquer eighty-five countries, considering himself a saint or preacher. He also believed a deputy was carrying a virus transferable from computers to humans, which he feared contracting during a police visit. The Defendant thought the CIA held meetings in a Nashville church two months before the shooting. He was detained from 1995 to 2006 before being deemed competent for trial. Dr. Ronnie Stout noted his slow progress due to challenges in finding suitable medication. The trial court found the Defendant guilty of first-degree murder, attempted first-degree murder, and two counts of second-degree murder, sentencing him to life imprisonment plus fifteen years. The Defendant appeals, arguing the trial court improperly required him to prove both that he could not appreciate the nature and the wrongfulness of his actions for an insanity defense, and that consecutive sentences were unjust. The State contends sufficient evidence indicated the Defendant knew his actions were wrong. Appellate review of the insanity defense rejection is stringent, requiring reversal only if no reasonable trier of fact could conclude the Defendant was insane at the time of the offense. This standard applies to both jury and bench trials.
The statutory requirements for an insanity defense in Tennessee, as outlined in Tennessee Code Annotated section 39-11-501, specify that a defendant can assert this defense if, at the time of the offense, they were unable to appreciate the nature or wrongfulness of their actions due to a severe mental disease or defect. The burden of proof lies with the defendant, who must establish the insanity defense by clear and convincing evidence. Courts interpret statutory language using its natural and ordinary meanings unless specified otherwise by the legislature.
In this case, the interpretation of 'or' within the statute indicates that the defendant can successfully assert an insanity defense by proving either an inability to appreciate the nature of their acts or the wrongfulness of their acts, not both. Testimony from several doctors indicated that the defendant, suffering from paranoid schizophrenia, believed he had ownership over the world and perceived threats from law enforcement, leading him to act in self-defense. Notably, the defendant claimed he did not engage in illegal behavior, suggesting he was unaware of the illegality of shooting police officers serving a warrant.
Despite expert testimony supporting the claim that the defendant could not appreciate the wrongfulness of his actions, the trial court found that he failed to demonstrate he could not appreciate the nature of his acts. The court examined the evidence and expert opinions, concluding that the defendant did not meet the burden of proof required for the insanity defense. Consequently, the court found the defendant guilty of first-degree murder, attempted first-degree murder, and two counts of attempted second-degree murder.
The trial court's finding regarding the Defendant's ability to appreciate the wrongfulness of his actions is deemed ambiguous, leaving uncertainty about whether the court was summarizing or accrediting expert testimony on the Defendant's mental state. This ambiguity prevents a thorough review of the court's legal conclusions. As a result, the case is remanded for clarification of the trial court's factual findings. If the court finds the Defendant, due to severe mental disease or defect, could not appreciate the wrongfulness of his actions, it should vacate the convictions and enter a verdict of 'Not Guilty by Reason of Insanity'. Conversely, if the Defendant fails to prove this by clear and convincing evidence, the court must include this determination.
Regarding consecutive sentencing, the State argues the Defendant qualifies as a dangerous offender, justifying consecutive sentences. When a defendant contests the sentence, the appellate court conducts a de novo review, presuming the trial court's factual determinations are correct unless proven otherwise. The appellate court will consider all evidence presented, the presentence report, sentencing principles, arguments, the nature of the offense, mitigating or enhancing factors, and the Defendant's statements and potential for rehabilitation. The trial court may impose consecutive sentences if it finds, by a preponderance of the evidence, that the Defendant is a dangerous offender whose actions show little regard for human life, while also determining that consecutive sentences are necessary for public protection and align with the severity of the offenses.
In State v. Wilkerson, the trial court deemed the Defendant a dangerous offender due to a murder, a serious injury to another individual, and the potential for harm to two others. The court imposed a consecutive sentence of life plus fifteen years. Although the court did not make specific findings (Wilkerson findings), the decision to run the sentences consecutively was upheld. The Defendant had secretly kept two guns in his residence and shot two police officers upon their arrival to serve an eviction warrant, killing one and seriously injuring another. After barricading himself and refusing to negotiate with a SWAT team, he attempted to wrestle a weapon from an officer. The lengthy sentence was justified to protect the public and corresponded with the severity of his offenses. The court found no merit in the Defendant's challenge to the sentencing. However, it noted ambiguities in the trial court's findings regarding the Defendant's insanity defense, prompting a remand to clarify these findings.
