Insanity Defense, Review of Jury’s Decision to Reject

Unless otherwise indicated, all indented material is copied directly from the court’s opinion.

Decisions of the Tennessee Supreme Court

Decisions of the Tennessee Court of Criminal Appeals

State v. Elrod, No. E2021-00622-CCA-R3-CD, p. 10  (Tenn. Ct. Crim. App. Mar. 28, 2022).

“[A]ppellate courts in Tennessee should reverse a jury verdict rejecting the insanity defense only if, considering the evidence in the light most favorable to the prosecution, no reasonable trier of fact could have failed to find that the defendant’s insanity at the time of the offense was established by clear and convincing evidence.” State v. Flake, 88 S.W.3d 540, 554 (Tenn. 2002). This reasonableness standard of review is similar to the standard reviewing courts apply when assessing the sufficiency of the evidence. Id. This Court, in applying the reasonableness standard, “should consider all the evidence in the record in the light most favorable to the [S]tate in determining whether the jury appropriately rejected the insanity defense.” Id. When the evidence is disputed, this Court “should rarely reverse a jury’s rejection of the insanity defense under this deferential standard of review.” Id. at 556.


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