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Louisiana v. Wayne Robert Felde

422 So. 2d 370 (1982)

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Louisiana v. Wayne Robert Felde

Louisiana Supreme Court

422 So. 2d 370 (1982)

Facts

Wayne Robert Felde (defendant) was previously convicted of manslaughter and assault in Maryland for killing his friend. Felde was serving a 12-year sentence when he escaped to Louisiana to see his mother, who was dying of terminal cancer. Felde’s mother died. Later, Felde was told by his sister that a police officer was looking for him. Felde purchased a gun that he placed in the waistband of his pants and waited in a bar for his friends to pick him up. Felde consumed a lot of alcohol over six hours, and after his friends failed to show up, Felde called a taxi. A bar patron called the police, reporting that a man had a gun. Police officers were checking another man when Felde went outside to meet the taxi. The patron informed the officers that Felde was the man with the gun, but when officers searched Felde they did not find a gun. The taxi driver refused to give Felde a ride due to his level of intoxication, and Felde was arrested for being drunk. While handcuffed in the back of the police car, Felde grabbed his gun. Felde stated that he was trying to shoot himself, but the officer driving the car braked quickly, and as a result, the officer was shot. The officer died. Felde escaped and was found with his reloaded gun by another officer, who shot Felde multiple times. Due to the gunshot wounds Felde sustained, Felde had surgery and several internal organs had to be removed. Felde pleaded not guilty by reason of insanity, stating that he suffered from post-traumatic stress disorder (PTSD) due to his military service in Vietnam. Felde was evaluated by three physiatrists, who found Felde competent to stand trial and sane at the time of the crime. Felde’s family testified that Felde became irritable, moody, and depressed after his service in Vietnam but that he refused psychiatric help. Felde’s expert witness testified that Felde suffered from PTSD and that the death of Felde’s mother likely triggered a dissociative incident, as Felde told the doctor that he saw flashes and heard gunshots before the gun went off. The doctor testified that Felde likely purchased the gun to feel safe after his mother died and believed that Felde was trying to kill himself when the officer was shot. The doctor recommended that Felde receive group therapy with other veterans and stated that Felde would likely kill himself or another person if let free. Two other experts agreed that Felde was suffering from PTSD and had bought the gun to kill himself. Felde was found guilty of first-degree murder and sentenced to death. Felde appealed, arguing that the trial court had committed 50 errors.

Rule of Law

Issue

Holding and Reasoning (Watson, J.)

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