## Facts

- Patricia Tempest had a longstanding history of severe mental illness, including depression, multiple suicide attempts, repeated psychiatric hospitalizations, and a later schizophrenia diagnosis.
- On June 18, 1976, while at home with her six-year-old son Gregory, she prepared him for a kindergarten event and drew him a bath.
- During the bath, she held Gregory under water and drowned him; she left him in the tub to ensure he was dead.
- Afterward, she engaged in routine activities (watching television, eating, taking medicine) and later calmly told her husband she had drowned their son.
- Police described her as calm, coherent, and articulate; she confessed and gave motives including resentment that her husband and son had friends and she did not, and a desire to avoid future social interaction tied to her son starting first grade.
- When asked by police whether she knew what she did was wrong, she stated that she knew it was wrong.

## Issues

1. Whether the evidence was sufficient for the fact-finder to conclude beyond a reasonable doubt that Tempest was legally sane at the time of the killing under Pennsylvania’s then-applicable insanity standard.
2. Whether the evidence was sufficient to prove the specific intent to kill, deliberation, and premeditation required for first-degree murder despite evidence of serious mental illness.

## Decision

- The Supreme Court of Pennsylvania affirmed the judgment of sentence for first-degree murder.
- The Court held the Commonwealth presented sufficient evidence for the trial judge, as fact-finder in a bench trial, to find Tempest legally sane beyond a reasonable doubt.
- The Court held the record supported a finding of specific intent to kill and the elements of first-degree murder beyond a reasonable doubt.

## Legal Principles

- Once a defendant introduces evidence of insanity under Pennsylvania law at the time, the Commonwealth must prove sanity beyond a reasonable doubt under a M’Naghten-type standard (capacity to understand the nature and quality of the act and to know it is wrong).
- On sufficiency review, the evidence is viewed in the light most favorable to the Commonwealth as verdict winner, asking whether the fact-finder could find each element beyond a reasonable doubt.
- Sanity is a fact question; the fact-finder may accept or reject expert psychiatric testimony, in whole or in part, and resolve conflicts in the evidence.
- Serious mental illness, including schizophrenia, does not itself establish legal insanity; admissions and conduct showing awareness of wrongfulness and organized behavior may support a finding of sanity.
- Evidence of planning, purposeful conduct, coherent post-offense behavior, and stated motives may support a finding of specific intent and first-degree murder notwithstanding mental abnormality.

## Conclusion

The court upheld Tempest’s first-degree murder conviction because the trial judge could reasonably find, based on expert testimony and strong non-expert evidence—including her calm confession and admission that the act was wrong—that she was legally sane and formed the specific intent to kill.


Commonwealth v. Tempest, 437 A.2d 952 (Pa. 1981)