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State v. Arriola

Court of Criminal Appeals of Tennessee
2009 Tenn. Crim. App. LEXIS 728 (Aug. 26, 2009)


Facts

Richard Arriola (defendant) suffered from paranoid schizophrenia. Arriola was hospitalized for treatment three times between 1987 and 1991. The third hospitalization was judicially ordered after a physical altercation. Because of Arriola’s schizophrenia, he suffered from mental delusions and paranoia. After Arriola was released from hospitalization, he lived in his parents’ basement and did not continue treatment. In 1995, Arriola’s parents decided to serve Arriola with an eviction warrant, believing the judge would order Arriola to be committed to treatment. When police served the warrant, Arriola shot at the officers with a handgun and later with a shotgun. One officer was killed. Arriola retreated back into the house, and the Special Weapons and Tactics (SWAT) team was called to the scene. When the SWAT team attempted to penetrate the house, Arriola fired more shots. Arriola was charged with one count of first-degree murder and multiple counts of attempted murder. Arriola was not deemed competent for trial until 2006. While in custody between 1995 and 2006, multiple doctors observed that Arriola suffered from severe hallucinations and delusions. The doctors believed that, due to these delusions, Arriola was unable to understand the wrongfulness of his conduct at the time of the shootings. Despite testimony to that effect, Arriola was convicted on all charges. On appeal, the Court of Criminal Appeals of Tennessee remanded to the trial court for clarification of the trial court’s factual findings about Arriola’s insanity defense. The trial court’s response relied on the belief that an understanding of the wrongfulness of an act was encompassed by an understanding of the nature of the act. Arriola appealed on the ground that the trial court applied the incorrect legal standard for an insanity defense.

Rule of Law

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Issue

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Holding and Reasoning (Wedemeyer, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
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