## Facts

- A neighbor reported gunshots from Stephen Ruffin’s rural property in Coryell County, Texas.
- Deputies responded, observed a bloody dog that appeared to have been shot, and heard additional shots from inside the residence.
- Ruffin yelled from the woods for officers to leave; more officers and a SWAT team arrived.
- During a standoff, Ruffin fired multiple shots in the direction of officers and made statements described as bizarre and delusional.
- Ruffin was indicted for nine counts of first-degree aggravated assault on a public servant, requiring proof he intentionally or knowingly assaulted police officers who were lawfully discharging official duties.
- Ruffin did not assert legal insanity; he claimed psychotic delusions caused him to believe he was shooting at “Muslims” trying to kill him, not police officers.
- The defense sought to present psychologist testimony that Ruffin suffered psychotic symptoms, had impaired perception and judgment, and did not know he was shooting at law-enforcement officers.
- The trial court excluded the expert testimony on the view that such mental-disease evidence was admissible only in homicide cases or when the defendant raised insanity.
- The jury convicted Ruffin on nine counts and assessed ten years’ imprisonment on each; the intermediate court affirmed.

## Issues

1. Whether expert testimony about a defendant’s mental disease and delusional beliefs is admissible when offered to directly negate the specific mens rea that the defendant intended to assault a public servant.
2. Whether excluding such testimony solely because the case is not a homicide prosecution and the defendant did not plead insanity is an abuse of discretion.

## Decision

- The Texas Court of Criminal Appeals reversed the court of appeals and remanded.
- The court held the trial court abused its discretion by excluding the psychologist’s testimony.
- The court ruled that both lay and expert evidence of mental disease or defect is relevant and admissible when it directly rebuts the particular mens rea required for the charged offense, absent exclusion by a specific evidentiary rule.
- The court emphasized that the evidence could negate the public-servant element while leaving possible liability for aggravated assault based on intent to shoot at a person.

## Legal Principles

- Texas does not recognize a freestanding diminished-capacity or diminished-responsibility defense apart from statutory insanity.
- Evidence of mental disease or defect may nevertheless be admitted to contest whether the defendant actually formed the specific intent or knowledge required by the charged offense.
- Such mental-illness evidence is admissible across offenses, not limited to homicide cases, when it directly rebuts the relevant mens rea element.
- In aggravated assault on a public servant, evidence showing the defendant did not know the target was a police officer can negate the public-servant enhancement even if the defendant intended to shoot at a person.

## Conclusion

The court held that excluding expert testimony about Ruffin’s psychotic delusions was error because it directly bore on whether he knew he was shooting at police officers, a required mens rea for first-degree aggravated assault on a public servant; the case was reversed and remanded for further proceedings with that evidence admissible for the mens rea question.


Ruffin v. State, 270 S.W.3d 586 (Tex. Crim. App. 2008)