People v. Santarelli
New York Court of Appeals
401 N.E.2d 199 (1980)

- Written by Sean Carroll, JD
Facts
Joseph Santarelli (defendant) killed his brother-in-law. At trial, Santarelli asserted an insanity defense and produced lay and expert testimony to support this claim. To rebut this defense, the prosecution (plaintiff) introduced expert testimony that Santarelli suffered from a personality disorder known as explosive personality. According to the expert testimony, explosive personality could result in behavioral outbursts but did not rise to the level of delusional psychosis, which would qualify for the insanity defense. To further this line of argument, the prosecution introduced testimony of laypeople who had witnessed Santarelli react to situations in violent, irrational ways. Specifically, a witness testified that Santarelli had been in a bar fight, although the witness was unable to say how the fight started. Another witness testified that Santarelli had beaten up a teamster shop steward as part of a preplanned attack. Finally, Santarelli’s probation officer testified that Santarelli had previously been convicted of possession of a sawed-off shotgun and that he had on several occasions reacted violently in the face of mild provocation. Santarelli was convicted, and he appealed, arguing that the prosecution’s lay testimony about his prior violent acts was improperly admitted. The appellate court affirmed. Santarelli appealed.
Rule of Law
Issue
Holding and Reasoning (Gabrielli, J.)
Dissent (Jasen, J.)
What to do next…
Here's why 832,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.