Van Guilder v. State

Citations: 674 S.W.2d 915; 1984 Tex. App. LEXIS 5927Docket: 04-83-00109-CR

Court: Court of Appeals of Texas; July 25, 1984; Texas; State Appellate Court

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Joyce Ann Van Guilder was convicted of attempted murder and sentenced to twenty years in prison following a jury trial. She was indicted on five charges related to a single incident, including one for murder and four for attempted murder, to which she pleaded not guilty by reason of insanity. The jury found her guilty of the first offense and not guilty by reason of insanity for the others, despite evidence clearly establishing her actions during the incident. 

On the day of the offenses, Van Guilder entered Sterling Ditzler's apartment and shot him, wounded two women in an adjoining kitchen, and later shot two occupants in a second apartment, claiming Ditzler was responsible for a woman's death. After the shootings, she fled and was apprehended after sustaining severe injuries from a fall. 

Van Guilder raised two grounds of error on appeal: the jury's verdict was against the weight of the evidence and contrary to the law due to her established insanity defense. Evidence presented included testimony from friends, family, and medical professionals detailing her traumatic background, mental health struggles, and a diagnosis of chronic schizophrenia. At the time of her arrest, she exhibited confusion and delusions, believing she was in danger and involved in a race. Medical experts ruled out malingering as a factor in her mental state during the incident.

Appellant exhibited illogical thinking and delusions, including identifying as a biblical character and feelings of persecution related to her sexuality. Dr. Mohl diagnosed her with schizophrenia of the paranoid type. Dr. James O. Sherman, a psychologist, confirmed this diagnosis based on psychological tests, stating that appellant was unable to appreciate the wrongfulness of her actions or conform her behavior to legal standards at the time of the incident. Dr. John Sparks, a psychiatrist, echoed this assessment, asserting that appellant's mental disease prevented her from recognizing her actions as wrong. Dr. Franklin Redmann, answering a hypothetical scenario based on trial evidence, concluded that the individual described would be incapable of discerning right from wrong due to mental illness. The State did not present rebuttal evidence regarding the insanity defense, claiming it was an affirmative defense they were not obligated to negate, referencing relevant case law and Texas Penal Code. However, unlike a previous case (Madrid), where the defense had limited evidence, the current defense presented five credible doctors without effective cross-examination. The State acknowledged having consulted another doctor who supported the diagnoses of Drs. Sparks and Sherman, further affirming that appellant's paranoid schizophrenia hindered her ability to comply with legal standards at the time of the offense.

The appellant's evidence and testimony regarding insanity significantly differ from the case of Madrid. In Graham, the court acknowledged that a jury verdict of sanity could be upheld despite conflicting medical testimony, which was ambiguous and based on limited observations. In the current case, Dr. Mohl stated that psychiatric staff had continuous involvement with the appellant from her arrival at the emergency room. The appellant's behavior was noted by her landlady the day before the offenses, including a belief that a new acquaintance was her sister and a confession of remembering killing a man. The morning before the offenses, the appellant exhibited unusual behavior, appearing distressed. Following the offenses, a paramedic observed the appellant throwing her wallet away, despite her denial of doing so, and she resisted going to the hospital. The appellant claimed to not know her identity and spoke of needing to save children. The presence of incriminating evidence and her ability to describe the weapon indicated some level of awareness. Although attempts to conceal evidence can suggest sanity, the State admitted there was no lay testimony supporting a sanity finding. Jurors have the discretion to favor lay witness testimony over expert opinions, as seen in Graham, which highlights that their conclusions can be based on the facts presented, even if they do not align with expert testimony. The current case presents significant differences from Graham that warrant a different conclusion regarding the appellant's mental state.

No medical or lay testimony supports a finding that the appellant was sane at the time of the offense. While acknowledging that inconsistent verdicts typically do not warrant reversal, the court does not base its decision on this inconsistency. Instead, it emphasizes that the evidence favoring the appellant's claim of insanity is the same evidence that influenced the jury on other verdicts. The State argues that the court lacks jurisdiction over the weight and preponderance of evidence concerning factual issues, referencing previous case law. However, the court clarifies that jurisdiction over such factual determinations has been established since a constitutional amendment. The jury's general verdict of guilty necessarily implied a finding of sanity, but the court finds no evidence supporting this. Consequently, the court holds that the appellant has proven insanity as a matter of law, sustaining the appellant's claim that the verdict is contrary to the evidence. The trial court's judgment is reversed, and the appellant is declared not guilty by reason of insanity, with the court retaining jurisdiction for further disposition. The court also notes that the jury's sanity finding is against the great weight and preponderance of the evidence, indicating that had they addressed this point, a remand for a new trial would have been warranted.