State v. Brom

David Brom's (defendant) parents and siblings were found dead in their home from numerous gash wounds, and the ax used in the killings, bearing Brom's fingerprints, was found in the basement. Brom was charged with four counts of first-degree murder and pleaded both not guilty and not guilty by reason of insanity, triggering a bifurcated trial under Minnesota law. In the guilt phase, Brom sought to introduce expert psychiatric testimony to show he was incapable of premeditation, but the trial court excluded it and instructed the jury not to consider his mental illness during that phase; the jury found him guilty of all four counts. In the second, insanity phase, Brom bore the burden of proving mental illness by a preponderance of the evidence, and while all four psychiatrists who testified agreed he suffered some mental impairment, two concluded he was not legally insane; the jury again found him guilty, and he received four life sentences. Brom appealed, arguing exclusion of the psychiatric testimony in the guilt phase violated due process.