United States v. Bright – Case Brief
United States v. Bright, 517 F.2d 584 (2d Cir. 1975).
Facts: Fred Scott gave Bright (D) nine welfare checks that had been stolen from the U.S. mail. Bright admitted at trial that she cashed the checks but claimed that she did not know they had been stolen. Bright testified that Scott had claimed that had had been given the checks as payment for debts or rent owed to him.
Bright’s conviction on three counts of possession of stolen mail was based on three checks she cashed after one was returned unpaid. Bright sought to introduce expert testimony that while she did not suffer from mental illness, she had character flaws and suffered from a passive dependent personality disorder. The lower court did not allow the testimony at trial and Bright appealed her conviction, asserting that exclusion of the evidence was reversible error.
Issue: Are personality disorders not amounting to insanity admissible to show lack of mens rea?
Holding and Rule: No. Personality disorders not amounting to insanity are not admissible to show lack of mens rea.
The expert witness was prepared to testify that Bright was a gullible person, but a person unaffected either by psychosis or neurosis. There was no proffered testimony to show that Bright did not have the capacity to form a specific intent to commit the crime. All humankind is heir to defects of personality. We cannot allow such evidence to take us beyond the boundaries of conventional psychiatric opinion testimony.
Disposition: Reversed on other grounds.
See Breunig v. American Family Ins. Co. for a law school torts case brief holding that, to claim insanity as a defense to negligence, the mental illness must affect the person’s ability to understand and appreciate the duty to act as a reasonable person, and there must be no warning that the person is subject to such an event.