Payne v. StateAnnotate this Case
The Supreme Court reversed Defendant's guilty but mentally ill (GBMI) conviction to find him not guilty of reason of insanity (NGRI), holding that the State presented insufficient demeanor evidence with which to rebut the unanimous expert opinion and evidence of Payne's history of mental illness.
In 2005, Defendant confessed to burning down two bridges and attempting to burn another. Defendant spent most of his life under psychiatric care for chronic paranoid schizophrenia and delusional disorder. The trial court found Defendant incompetent to stand trial until 2016. At his jury trial, Defendant asserted the insanity defense. Three mental health experts concluded that Defendant was unable to distinguish right from wrong. Nevertheless, the jury rejected the insanity defense and found Defendant GMBI on all counts. The court of appeals affirmed. The Supreme Court reversed the GBMI conviction to find Defendant NGRI, holding that the well-documented and consistent history of Defendant's mental illness, along with the unanimous expert opinion, leads to the conclusion that Defendant was insane when the crimes were committed.