Greenfield v. Robinson

In 1973, a Virginia jury convicted Ronald Greenfield (defendant) of second-degree murder for the stabbing of Mary Frances Jordan. At trial, Greenfield raised an unconsciousness defense. Greenfield testified that he had used heroin and a hallucinogenic drug on the night of Jordan’s murder. Dr. Kenneth Locke, a psychiatrist, testified that he had interviewed Greenfield to attempt to diagnose Greenfield’s medical condition and had hypnotized Greenfield to help him recover his memory of the night of Jordan’s murder. The trial court barred Locke from relaying what Greenfield had said while in a hypnotic trance. Locke opined that Greenfield was unconscious at the time of Jordan’s homicide, but Locke did not express an opinion regarding the cause of Greenfield’s unconsciousness. The trial court also refused to allow Locke to question Greenfield on the witness stand after placing Greenfield under a hypnotic trance. The record reflected that had hypnotic testimony not been barred, Locke would have testified that Greenfield’s recovered memories included chasing another man from the scene. Greenfield appealed from his conviction, and the Virginia Supreme Court affirmed the conviction. Greenfield then filed a federal habeas petition, arguing in relevant part that the Virginia courts had erred by refusing to allow Greenfield to testify while under hypnosis and refusing to allow Locke to testify regarding statements Greenfield made while under hypnosis. Greenfield relied upon Chambers v. Mississippi, 410 U.S. 284 (1973), to argue that if no eyewitness exists, a trial court’s refusal to admit a defendant’s statements made under hypnosis violates the defendant’s constitutional right to due process.