United States v. Taylor

John Robert Taylor (defendant) was a convicted felon with a history of schizophrenia and severe alcohol abuse. On April 3, 2015, a police officer attempted to arrest Taylor for public intoxication. Taylor tried to fire a gun at the police officer and, while being arrested, threw the gun into a vehicle parked nearby. Taylor was charged as a felon in possession of a gun in violation of 18 U.S.C. § 922(g)(1). Taylor notified the court that he planned to plead not guilty by reason of insanity, citing his schizophrenia and alcohol abuse. A psychologist examined Taylor and could not conclusively determine whether he suffered from a severe mental disease or defect that prevented him from understanding the nature of his offense. The psychologist noted that Taylor had not received treatment for his schizophrenia in 20 years. The psychologist determined that rather than Taylor suffering from schizophrenia, Taylor’s actions were primarily caused by his long-term severe alcohol abuse. The psychologist noted that alcoholism was a substance-use disorder recognized by the medical community as a chronic illness. A friend of Taylor’s testified that in the days before Taylor pulled the gun on the police officer, Taylor had been talking to himself and acting unusually. Taylor did not, however, present evidence of his level of intoxication at the time of the incident. The United States government (plaintiff) opposed Taylor’s insanity defense, relying on Poolaw v. United States to argue that alcoholism was not a severe mental illness or defect that could support an insanity defense.