Jason L. Bloomfield v. State of Indiana

Citations: 61 N.E.3d 1234; 2016 Ind. App. LEXIS 359; 2016 WL 5601331Docket: 02A05-1601-CR-112

Court: Indiana Court of Appeals; September 30, 2016; Indiana; State Appellate Court

Original Court Document: View Document

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Jason L. Bloomfield appeals his convictions for two counts of level 5 felony battery against a public safety official resulting in bodily injury and one count of level 6 felony battery against a public safety official. He challenges the sufficiency of the evidence supporting the jury's rejection of his insanity defense. The court notes conflicting expert testimony regarding Bloomfield's ability to appreciate the wrongfulness of his actions and whether his mental state stemmed from a mental disease or voluntary intoxication, concluding that sufficient evidence supported the jury's finding of legal sanity at the time of the offenses.

In 2014, Bloomfield regularly abused Xanax and Spice. Following his arrest on July 3, 2014, for unrelated charges, he was observed to have sustained a facial injury and reported his drug use during a health screening at the Allen County Jail. He was placed under medical observation for withdrawal symptoms. During his incarceration, he exhibited increasingly erratic behavior, including hallucinations and self-neglect, leading to hospitalization for anxiety and withdrawal.

On July 7, during morning roll call, Deputy Christopher Depew opened Bloomfield's cell door. Bloomfield, naked, attacked Deputy Depew by biting his arm and attempted to seize the deputy's microphone, prompting Depew to seek safety by retreating to the shower room until backup arrived.

Deputies Chad Ray and Richard Wacasey responded to a call for assistance and found Bloomfield lying on the floor. Upon seeing the deputies, Bloomfield assumed a fighting stance. Deputy Ray subdued him, but Bloomfield attempted to bite him and then squeezed Deputy Ray's testicles. In response, Deputy Ray yelled and punched Bloomfield, while other officers handcuffed him. Despite being restrained, Bloomfield continued to resist and attempt to bite the officers. A restraint chair was used to secure him, during which he spat at Deputy Wacasey, prompting the officers to place a spit hood on him.

Bloomfield faced charges of two level 5 felony counts of battery of a public safety official resulting in bodily injury and one level 6 felony count of battery of a public safety official. He filed a notice of intent to claim temporary insanity. The trial court appointed three doctors to assess Bloomfield's competency and sanity, all concluding that he was competent to stand trial.

During a three-day jury trial, Dr. Lombard testified that Bloomfield appeared cognitively clear during an examination but could not assess his state of mind on the incident date due to lack of memory of the events. He noted behaviors consistent with withdrawal from Xanax and Spice. Dr. Ross, who examined Bloomfield later, described him as anxious but not psychotic or aggressive, attributing his behavior to withdrawal effects from the substances. Dr. Ross indicated that Bloomfield's temporary withdrawal symptoms could have diminished his capacity to appreciate the wrongfulness of his actions, though he also suggested that Bloomfield's behavior could be partly volitional due to anger. Dr. Ross found no evidence of a chronic psychological condition, although he acknowledged Bloomfield's previous prescription for an antipsychotic medication.

Dr. Wieland examined Bloomfield on December 19, 2014, and testified that Bloomfield was suffering from bipolar disorder with psychotic episodes during the attacks, indicating he was not completely sane. However, at the time of the examination, Bloomfield was not experiencing a manic or psychotic episode. Dr. Wieland noted that withdrawal from illicit drugs could induce psychosis and acknowledged that behaviors discussed in a hypothetical scenario could stem from drug withdrawal. He also indicated that Bloomfield had inaccurately reported his drug use, omitting Xanax and misrepresenting his marijuana use. Dr. Wieland's conclusion of Bloomfield's incomplete sanity was partly based on the self-reported drug usage, and the claim of methamphetamine use was unsupported by the record.

Bloomfield was convicted and sentenced to eight and a half years, with seven years executed and eighteen months suspended to probation. He appealed, arguing the evidence was insufficient to support the jury's rejection of his insanity defense, which requires the defendant to prove, by a preponderance of the evidence, that he suffered from a mental disease that impaired his ability to appreciate the wrongfulness of his conduct. The definition of mental disease excludes conditions arising solely from voluntary intoxication. 

Insanity determinations are for the trier of fact, and an appellate court will only reverse if the evidence unequivocally demonstrates insanity at the time of the crime. The court does not reweigh evidence or assess credibility but considers only favorable evidence. The presence of conflicting expert opinions regarding sanity supports the jury's decision against an insanity defense. Bloomfield argued that the expert evidence was uniform in concluding he was mentally impaired and unable to appreciate his conduct's wrongfulness.

Dr. Lombard did not provide an assessment of Bloomfield's state of mind during the offenses. Dr. Wieland diagnosed Bloomfield with bipolar disorder with psychotic episodes, asserting he could not appreciate the wrongfulness of his actions at that time. Conversely, Dr. Ross supported both elements of the insanity defense, noting Bloomfield’s prior prescription of Geodon, an antipsychotic, and suggesting his ability to recognize the wrongfulness of his actions was diminished during the offenses. However, Dr. Ross's awareness of the Geodon prescription did not imply he concurred with the diagnosis that warranted it. The record indicates Geodon could be prescribed for various conditions, but Bloomfield did not provide evidence to clarify the purpose of his prescription. Furthermore, prior prescription does not confirm that Bloomfield suffered from the same condition when committing the offenses. Importantly, Dr. Ross did not assert that Bloomfield was unable to appreciate the wrongfulness of his actions, highlighting that a diminished ability to do so does not equate to complete inability. Dr. Ross also disagreed with Dr. Wieland’s diagnosis, attributing Bloomfield's behavior on July 7 to withdrawal from Xanax and Spice, and found no evidence of a chronic psychological condition aside from substance abuse. He noted that Bloomfield's withdrawal may have impaired his anger control, suggesting he acted out of anger, which could indicate an awareness of the wrongfulness of his conduct.

Dr. Ross attributed Bloomfield's conduct to his withdrawal from Xanax and Spice, but Bloomfield contends that his actions stemmed from a mental degeneration due to his long-term substance abuse, qualifying for an insanity defense. He references the case of Berry, where the court acknowledged that voluntary intoxication leading to mental illness could absolve an individual from responsibility if it prevents them from understanding the wrongfulness of their actions. The court emphasized that not all chronic substance users develop a mental disease under Indiana's insanity statute, and the intersection of intoxication and insanity is complex. Although evidence indicated Bloomfield experienced withdrawal symptoms after his last drug use on July 2, 2014, the medical staff did not deem his condition severe enough for hospitalization. Evaluations by multiple doctors post-incarceration showed Bloomfield was normal, and none testified that his long-term drug use caused a mental disease. Consequently, the jury had sufficient grounds to reject Bloomfield's argument regarding mental illness, leading to the affirmation of his convictions. The court concluded that the evidence did not unequivocally support Bloomfield's claim of insanity.