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United States v. Brown

United States Court of Appeals for the Tenth Circuit

326 F.3d 1143 (2003)

Relevant factsFree

Edward Brown (defendant), charged with drug and firearms offenses, filed notice of an insanity defense supported by psychologist Dr. Fred Lindberg's proposed testimony that Brown's PTSD prevented him from making "correct choices" and conforming his conduct to legal requirements; the trial judge granted the government's motion to exclude this testimony because it failed to link Brown's PTSD to the specific mens rea required for the charged offenses, and though invited to proffer additional connecting evidence, Brown could not do so. Brown pleaded guilty conditioned on appealing this ruling.

IssueFree

Whether expert testimony that a defendant's PTSD prevented him from making "correct choices" and conforming his conduct to the law is admissible to support an insanity defense, absent a shown link to the specific intent required for the charged crime.

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