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United States v. Garcia

United States Court of Appeals for the Second Circuit
94 F.3d 57 (1996)


Facts

The federal government (plaintiff) prosecuted Felix Garcia for being a convicted felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1). Garcia asserted the insanity defense. The federal district court trial evidence established that Garcia, who had a long history of substance abuse and mental disorders, and who was drunk and high on drugs at the time, pulled a gun on a police officer. Garcia's psychiatrist testified that Garcia's unlawful conduct stemmed mainly from his mental disorders. The government's psychiatrist testified that Garcia acted primarily under the influence of drugs and alcohol. The judge refused Garcia's request that the jury be instructed to consider both his substance abuse and his mental disorders, if they found that the substance abuse caused or was caused by the mental disorders. Instead, the judge instructed the jury to accept Garcia's insanity defense only if they found that his mental disorders, rather than his substance abuse, were solely responsible for rendering Garcia unable to appreciate the nature or quality or wrongfulness of his acts on the day in question. The jury convicted Garcia. On appeal to the Second Circuit Court of Appeals, Garcia argued that the judge's insanity-defense instruction was reversible error.

Rule of Law

Issue

Holding and Reasoning (Walker, J.)

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