State v. Arriola
Court of Criminal Appeals of Tennessee
2009 Tenn. Crim. App. LEXIS 728 (Aug. 26, 2009)
Richard Arriola (defendant), suffering from paranoid schizophrenia with a history of hospitalizations, shot at and killed a police officer serving an eviction warrant his parents had sought hoping it would compel his commitment to treatment, and continued firing at a SWAT team that responded; found incompetent for trial until 2006, Arriola was ultimately convicted of murder and attempted murder despite expert testimony that his severe delusions prevented him from understanding the wrongfulness of his conduct at the time of the shootings. On remand for clarification of its insanity-defense findings, the trial court concluded that understanding an act's wrongfulness was encompassed within understanding its nature, and Arriola appealed that legal standard.
Whether a person's inability to understand the nature or the wrongfulness of the person's actions are separate grounds to support an insanity defense.