United States v. Brown

Korrigan Brown (defendant), charged with armed robbery of two stores, admitted the robberies but pleaded not guilty by reason of insanity, presenting two mental health experts who testified he suffered from bipolar disorder; the trial judge refused Brown's request to instruct the jury that a conviction required the government to prove beyond a reasonable doubt that he was not insane, instead instructing under the Insanity Defense Reform Act's § 17 framework that Brown bore the burden of proving insanity by clear and convincing evidence. The jury convicted Brown on all counts, and he appealed, arguing this burden allocation violated due process by relieving the government of proving every element of the offenses.