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United States v. Eff

524 F.3d 712 (2008)

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United States v. Eff

United States Court of Appeals for the Fifth Circuit

524 F.3d 712 (2008)

Facts

Ryan Eff (defendant) was a firefighter charged with arson after he confessed to igniting 20 fires in a national forest. At trial, Eff raised an insanity defense based on his diagnosis with Klinefelter’s Syndrome. In support of this claim, Eff sought to call two expert doctors to testify that his condition created behavioral issues that diminished his ability to appreciate the wrongful nature of his actions when he set the fires. The trial court excluded the testimony and would not instruct the jury on an insanity defense. As a result, Eff waived his jury trial and tried the case to the judge. Eff was convicted and sentenced to seven years in prison. On appeal, Eff argued that the court erred in excluding the testimony of his two experts.

Rule of Law

Issue

Holding and Reasoning (Benavides, J.)

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