Commonwealth v. Chatman
Virginia Supreme Court
538 S.E.2d 304 (2000)
- Written by Mary Katherine Cunningham, JD
Facts
Chatman (defendant), a 13-year-old, moved for a psychiatric evaluation to determine whether he was insane at the time of his criminal offense during a juvenile-delinquency proceeding. Chatman asserted that, on the day of the offense, a doctor found that Chatman displayed homicidal ideation. Chatman also claimed, two days after the offense, that a psychologist diagnosed him with a schizophreniform disorder. The Commonwealth of Virginia (plaintiff) contended that, as a 13-year-old juvenile, Chatman lacked a due-process right under the Fourteenth Amendment or under Virginia statute to assert an insanity defense. The trial court denied the motion and found Chatman delinquent. Chatman appealed to the court of appeals, which found an insanity defense available to an adult was also available to a juvenile as a requirement of due process and fair treatment. The commonwealth appealed.
Rule of Law
Issue
Holding and Reasoning (Kinser, J.)
Dissent (Koontz, J.)
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