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Frendak v. United States

408 A.2d 364 (1979)

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Frendak v. United States

District of Columbia Court of Appeals

408 A.2d 364 (1979)

Facts

Willard Titlow left his office and Paula Frendak (defendant), a coworker, departed just after him. Titlow was found fatally shot on the first floor of the building minutes later. Following the shooting, Frendak left Washington, traveling through Atlanta, Miami, Mexico, Spain, and other countries before being arrested in Abu Dhabi, United Arab Emirates. Authorities searched her baggage and found a .38-caliber pistol, 45 rounds of ammunition, two empty cartridges, and a pocketknife. Frendak was brought back to the District of Columbia, where she was indicted for the murder of Titlow in the first-degree. Before her trial, Frendak underwent a series of psychiatric examinations to determine her competency and, after the fourth hearing on the issue, Frendak was found to be suffering from a mental disorder but was otherwise able to cooperate with her counsel, possessed a rational and factual understanding of the proceedings against her, and was fully aware of the charges. The trial court concluded that Frendak was competent to stand trial but reserved the right to raise the issue of competency at any point in the proceedings. Frendak refused to raise the insanity defense at trial and was found guilty of first-degree murder. Troubled, the trial court thereafter conducted hearings on the question of her criminal responsibility, which revealed that, at the time of Titlow’s murder, Frendak had been suffering from a mental illness that impaired her behavioral controls to such an extent that she could not appreciate the wrongfulness of her conduct and could not conform her conduct to the requirements of the law. As a result, the trial court decided, over Frendak’s objection, to interpose the insanity defense. The jury then found Frendak not guilty by reason of insanity. Frendak appealed, challenging the trial judge’s decision to raise the insanity defense on Frendak’s behalf over her objection.

Rule of Law

Issue

Holding and Reasoning (Ferren, J.)

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