A Pike County man challenging the jury’s finding that he was not insane or mentally ill did not meet what the Indiana Supreme Court acknowledged was a “heavy burden” to overturn the guilty verdict.
Andrew Satterfield appealed his convictions and sentence of life imprisonment without parole. The state charged him with murder, a felony; arson, a Class B felony; and attempted arson, a Class B felony, for killing his mother and burning down her house in December 2011.
At trial, Satterfield claimed he was not responsible by reason of insanity or was guilty but mentally ill. The jury rejected his defense and found him guilty.
Before the Supreme Court, Satterfield argued the jury’s decision not to find him insane or guilty but mentally ill was contrary to law. The unanimous panel disagreed.
Citing Myers v. State, 27 N.E.3d at 1076 and Hurst v. State, 699 N.E.2d at 654, Chief Justice Loretta Rush, writing for the court, held the jury has the right to disbelieve expert testimony of a defendant’s insanity or mental illness and rely instead on other evidence like demeanor, lay opinion testimony, and the circumstances of the crime. Juries may consider the additional evidence to either accept or reject expert testimony even when the expert testimony is unanimous.
In Satterfield’s case, the Supreme Court pointed out the three experts were not in consensus. They disagreed over whether Satterfield was schizophrenic and whether he was insane at the time of the crime.
Moreover, the non-expert evidence contradicted Satterfield’s defense. The Supreme Court noted that the jury was also presented with evidence that he did not seek immediate medical attention for his severe burns because he did not want to attract the police; he changed his story as to why he shot his mother; and he did not disclose his prior psychiatric commitment when he applied for a handgun license in 2010.
Consequently, the Supreme Court gave substantial deference to the jury.
“In view of the disputed evidence – both expert and non-expert – taken as a whole, we cannot say the evidence is without conflict on both Satterfield’s insanity and mental illness, and so we affirm the jury’s verdict as not contrary to law,” Rush wrote in Andrew S. Satterfield v. State of Indiana, 63S00-1401-LW-306.