People v. Steele

Steele (defendant) was convicted of first-degree murder and sentenced to death after presenting PTSD-related expert testimony connecting his Vietnam War trauma and brain abnormalities to the crime, including evidence a police helicopter flew over his home the night of the murder. He moved for a new trial based on juror declarations stating some jurors doubted the life-without-parole instruction and believed Steele might be paroled, and that jurors with military and Vietnam experience shared that background in concluding Steele did not actually suffer from PTSD or brain injury. The trial court excluded the declarations about jurors' subjective beliefs but considered and rejected the portions about what jurors said to each other, denying a new trial; the death sentence triggered automatic appeal.