State v. Sikora

Walter Sikora (defendant) grew up in foster care and suffered abuse as a child. As an adult, Sikora had difficulty holding a job or staying in a relationship. Sikora became emotionally dependent on a woman he was dating and was very upset when the woman ended the relationship. At a bar, Douglas Hooey and some other men harassed Sikora about the woman being available for other men and physically beat up Sikora. Sikora reported the assault to the police and then went home to get a handgun he owned. After test-firing the gun, Sikora returned to the bar, acting in a manner that witnesses described as automated, as if Sikora were acting without thinking. Sikora shot Hooey four times, killing him. Sikora went to the woman’s house to kill her, too, but the woman was not at home. The police arrested Sikora, and he was charged with first-degree murder. At trial, Sikora did not dispute that he was legally sane at the time of the killing. However, Sikora attempted to present testimony from a psychiatrist that Sikora’s background caused him to be triggered by the stress of the breakup and the beating in a way that removed his ability to think consciously and to make decisions of his own free will. Instead, Sikora’s actions were an automatic response to the events that had happened in his life before that point. Based on this testimony, Sikora argued that he had not acted of his own free will and could not have consciously premeditated the killing, which was a necessary element of first-degree murder. The trial court would not let Sikora present this defense, and the jury convicted Sikora of first-degree murder. On appeal, Sikora argued that he should have been allowed to present evidence that he was a victim of his genes and his circumstances and was not acting of his own free will at the time of the killing.