## Facts

- Allen C. Smith, an Army private stationed at Fort Richardson, had a documented history of mental illness and disciplinary problems and was referred multiple times to the base mental-health clinic.
- After learning he would be discharged soon, Smith entered a supply room, brandished a pistol, and demanded a vehicle to leave for the airport.
- Smith drove off the base, exchanged gunfire with military personnel, and fled from pursuing police.
- After abandoning the vehicle and hiding in the woods, Smith pointed his gun at a pursuing officer; when ordered to stop, Smith shot the officer, who returned fire and wounded Smith. Both survived.
- Smith was charged with shooting with intent to kill, wound, or maim and raised an insanity defense under Alaska’s test requiring lack of substantial capacity either to appreciate wrongfulness or to conform conduct to law.
- At a bench trial, three mental-health experts agreed Smith had schizophrenia and could appreciate wrongfulness; two opined he could not conform his conduct to law, while the State’s expert opined Smith’s conduct was goal-directed and consistent with purposeful behavior, supported by lay testimony.
- The trial judge rejected the insanity defense and convicted Smith; the conviction was affirmed on appeal, and the Alaska Supreme Court granted review.

## Issues

1. Whether a factfinder may find a defendant legally sane despite a numerical majority of expert testimony supporting insanity.
2. Whether the trial court clearly erred in finding the State disproved insanity beyond a reasonable doubt after the defendant produced substantial evidence raising the insanity issue.

## Decision

- The Alaska Supreme Court affirmed the conviction.
- The Court held a defendant may be found legally sane even when most expert witnesses support insanity.
- The trier of fact may credit one expert over others and may weigh expert testimony against lay testimony and observed conduct.
- The trial court’s sanity finding was not clearly erroneous because the State’s expert opinion, together with lay evidence of purposeful, goal-oriented actions, permitted a finding beyond a reasonable doubt that Smith had substantial capacity to conform his conduct to law.

## Legal Principles

- Once a defendant produces substantial evidence of insanity, the State bears the burden to disprove insanity beyond a reasonable doubt.
- Conflicting expert testimony on insanity is not resolved as a matter of law in the defendant’s favor; the factfinder determines credibility and weight.
- A factfinder may reject a majority of expert opinions and accept a minority expert view if supported by the record, including lay testimony and behavioral evidence.
- On appellate review, a trial court’s sanity determination following a bench trial is reviewed for clear error, and appellate courts do not reweigh competing expert opinions where the record supports the trial court’s choice.

## Conclusion

The Alaska Supreme Court upheld a bench-trial finding of sanity, ruling that the factfinder may credit one expert and corroborating lay evidence over multiple opposing experts, so long as the State disproves insanity beyond a reasonable doubt once the defense has introduced substantial evidence raising the insanity issue.


Smith v. State, 614 P.2d 300 (Alaska 1980)