United States v. Garcia (1996)
United States Court of Appeals for the Second Circuit
94 F.3d 57 (1996)
Felix Garcia (defendant), who had a long history of substance abuse and mental disorders, was prosecuted for being a felon in possession of a firearm after pulling a gun on a police officer while drunk and high. Garcia asserted the insanity defense; his own psychiatrist testified his unlawful conduct stemmed mainly from his mental disorders, while the government's psychiatrist testified Garcia was acting primarily under the influence of drugs and alcohol. The judge refused Garcia's request to instruct the jury that it could combine his substance abuse and mental disorders if it found the two were interconnected, instead instructing the jury to find insanity only if Garcia's mental disorders alone -- not his substance abuse -- rendered him unable to appreciate the wrongfulness of his conduct. Garcia was convicted and appealed, challenging that instruction.
Whether the federal insanity defense requires proof that the defendant's inability to appreciate the wrongfulness of his conduct arose solely from mental disease or defect, and not in any way from voluntary drug or alcohol abuse.