Washington v. Clark (Majority and Dissent)Annotate this Case
At his trial for premeditated first degree murder, petitioner Anthony Clark sought to introduce expert testimony regarding his intellectual deficits. Clark asserted this testimony would be relevant to contesting the State's mens rea evidence and to helping the jury understand Clark's affect while testifying. The trial court excluded Clark's proffered expert testimony, but it did allow relevant observation testimony about Clark's education history, Social Security disability benefits, affect, and actions on the day of the murder. The Supreme Court held that the trial court properly exercised its discretion in making its evidentiary rulings. The court did allow relevant observation testimony from lay witnesses to rebut the State's mens rea evidence, and Clark did not challenge the scope of this testimony on review. However, because Clark purposefully did not assert or plead diminished capacity and the proposed expert testimony was not relevant to any other purpose, the expert testimony was properly excluded. Clark also could not establish ineffective assistance of counsel or cumulative error, so the Court affirmed his convictions.