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COA: State has no burden to prove sanity

September 14, 2018

A man who unsuccessfully pursued an insanity defense failed to convince the Indiana Court of Appeals that the state had the burden of proving he was sane beyond a reasonable doubt.

Rodney Patterson of Muncie found guilty but mentally ill of a Level 1 felony charge of attempted murder after he shot Tong Ong, his apartment manager, in the chest. Refusing police orders to surrender, the special weapons and tactics team had to use a battering ram and detonated a distraction device to get into Patterson’s apartment and subdue him.

The state also charged him with unlawful possession of a firearm by a serious violent felon, a Level 4 felony; criminal recklessness, a Level 5 felony; and resisting law enforcement, as a Class A misdemeanor.

In rejecting Patterson’s argument that the state had the burden of proving his sanity, the Court of Appeals noted the Indiana Supreme Court had ruled in Thompson v. State, 804 N.E.2d at 1149, that the state did not need to disprove insanity.

The appeals panel also noted that medical experts at Patterson’s trial offered conflicting testimony as to his mental health. One of the medical doctors who evaluated Patterson found he suffered from mental illness but should have been able to understand that it was wrong to shoot another person.

The case is Rodney G. Patterson v. State of Indiana, 18A-CR-959.

 

 

 

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