Greenfield v. Commonwealth

A Virginia jury convicted Ronald Greenfield (defendant) of the second-degree murder of Mary Frances Jordan, a 21-year-old college student. In 1972, Jordan and 17-year-old Greenfield worked together at a restaurant. Greenfield testified that earlier on the night of Jordan’s murder, Greenfield had used heroin and psilocybin, a hallucinogenic drug. Jordan drove Greenfield home from work around 12:30 a.m. Greenfield felt a falling sensation as he left Jordan’s car, and the next thing that he could remember was lying on the ground 15 feet from Jordan’s car. After Greenfield got up, he saw a person running away from the car and saw Jordan motionless and bloody in the driver seat of the car. Greenfield took his pocketknife from the car’s floor. Greenfield testified that he then noticed that his hand was cut and fled from the scene, believing that he must have killed Jordan. Police arrested Greenfield a few hours later at a hospital where Greenfield had sought medical attention for the cut. According to police, Greenfield confessed to stabbing Jordan with the pocketknife that police found in his possession. At trial, Dr. Kenneth Locke, a psychiatrist, testified that he had interviewed Greenfield at the jail twice to diagnose Greenfield’s mental condition and that he had hypnotized Greenfield to help Greenfield recall what happened to Jordan. The trial court did not permit Locke to testify about what Greenfield said while under hypnosis. Locke opined that Greenfield was unconscious during the stabbing, but Locke testified that he had insufficient information to express an opinion on the cause of Greenfield’s unconsciousness. Greenfield appealed from his conviction, arguing in relevant part that the trial court had erred by preventing Locke from testifying about what Greenfield said while under hypnosis. Greenfield acknowledged that no Virginia law supported this argument but argued that the hypnotic evidence would have helped Greenfield fully develop his defense.