No error in rejecting insanity defense from woman who tried to drown child, COA affirms

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A jury wasn’t wrong in rejecting an insanity defense from a woman who stabbed a man and attempted to drown her 6-week-old child, the Court of Appeals of Indiana has affirmed.

Appellant-defendant Autumn Stahl began dating Stephen Blair in 2016 and gave birth to three children during the course of their relationship. Stahl already had two children before then. The youngest of the five, A.A., was born in June 2020.

Blair moved out of the home they shared in July 2020 because of issues with the relationship. He said that their relationship had been challenging because of Stahl’s “emotional problems and insecurities,” and that she could become “irrational.”

The following month, Stahl visited Blair at a house he was renovating, and Blair noticed she was “acting weird.”

Blair was concerned and went to Stahl’s home, where he found some of the children in the bathtub. Stahl asked him to give the children a bath and took A.A. into the bedroom.

Blair then noticed a burning smell and saw Stahl sitting on the bed rocking A.A. about three feet from a burning pillow.

Blair threw the pillow outside, and Stahl walked to the kitchen with A.A. There, she turned on the stove’s gas burners, but Blair turned them off.

Stahl then turned on the kitchen sink faucet and put her thumb inside of A.A.’s mouth to hold it open and placed the child’s face under the running water.

Blair got Stahl to the ground, but she stabbed him in the neck with a knife and continued to drown A.A. while Blair went to the front door to call for help.

Neighbors came and helped remove the other children. One neighbor saw Stahl trying to drown A.A. and asked her to hand the child over, which she did. A.A. survived.

Officers and paramedics then arrived. When they attempted to carry Stahl out of the house in a blanket, she told the paramedics to be careful because she recently had a cesarean section.

Stahl told a detective during an interview that she hadn’t slept in eight days leading up to the incident and that she had no support. She also said she hadn’t been “in her right mind” during the incident and never intended to hurt Blair or any of her children.

Stahl was charged Level 3 felony attempted aggravated battery, Level 5 felony battery with a deadly weapon, Level 3 felony aggravated battery, Level 6 felony domestic battery and two counts of Level 6 felony neglect of a dependent.

She was subsequently admitted to Parkview Behavioral Health, where she was diagnosed with post-traumatic stress disorder, post-partum depression and post-partum psychosis.

Stahl’s attorney filed a notice of defense of mental disease or defect and a motion for a psychiatric evaluation to determine her sanity or insanity at the time of the offenses. The Koskiusko Superior Court granted the motion and appointed a psychiatrist and a psychologist to examine Stahl.

The psychologist and psychiatrist both concluded Stahl “suffer[ed] from mental disease or defect which render[ed] her unable to sufficiently appreciate the wrongfulness of her conduct at the time of the alleged offenses.”

But a jury rejected Stahl’s insanity defense and found her guilty but mentally ill of all but Level 3 aggravated battery and the second count of Level 6 neglect of a dependent.

She was sentenced to a nine-year aggregate term.

On appeal, Stahl argued the jury erred in rejecting her insanity defense. She also argued there was insufficient evidence to support her convictions of Level 3 attempted aggravated battery and Level 5 battery with a deadly weapon.

The Court of Appeals disagreed.

Addressing the insanity defense, the appellate court ruled a reasonable jury could have inferred Stahl was able to appreciate the wrongfulness of her conduct at the time of the offenses. The opinion cites Stahl’s attempt to avoid arrest by retreating into her house when she heard sirens and her request that paramedics carry her with care.

Although the psychologist and psychiatrist concluded Stahl suffered from a mental disease or defect that had rendered her unable to appreciate the wrongfulness of her conduct at the time of the offenses, the Court of Appeals noted the separate evaluations were done 10 months and more than a year after the incident.

“It was within the province of the jury to give less weight to the expert testimony that relied upon evaluations of Stahl months after the incident than to the testimony of individuals actually present at the time of the offenses and videotaped interviews taken at the time of the offenses,” the opinion says.

Addressing the sufficiency of the evidence, the opinion says Stahl appeared to argue there was insufficient evidence to support the “substantial risk of death” element of the attempted aggravated battery conviction.

The appellate court wasn’t persuaded.

“Here, based on common sense and everyday living, the jury could have reasonably inferred that when Stahl held open her six-week-old son’s mouth and placed his face under a faucet of running water, she engaged in conduct that constituted a substantial step toward knowingly or intentionally inflicting an injury on the infant that created a substantial risk of death,” the opinion says.

For the Level 5 battery conviction, Stahl argued there was insufficient evidence that the knife she used to stab Blair was a deadly weapon.

“The fact that Stahl’s knife hit a fatty area of Blair’s neck and happened to miss a crucial organ or blood vessel does not alter the life-threatening nature of the weapon,” the opinion says.

Judge Rudolph Pyle wrote the opinion. Judges Nancy Vaidik and Paul Mathias concurred.

The case is Autumn B. Stahl v. State of Indiana, 23A-CR-143.

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