## Facts

- Richard Anthony Arriola suffered from paranoid schizophrenia.
- Arriola was hospitalized for psychiatric treatment three times between 1987 and 1991.
- Arriola’s third hospitalization was ordered by a court after a physical altercation.
- After his release, Arriola lived in his parents’ basement and did not continue mental-health treatment.
- Arriola experienced delusions, hallucinations, and paranoia associated with schizophrenia.
- In 1995, Arriola’s parents sought an eviction warrant, believing court involvement would result in Arriola being committed for treatment.
- When police came to serve the eviction warrant, Arriola shot at the officers, first with a handgun and later with a shotgun.
- One officer was killed during the encounter.
- Arriola went back into the house, and a SWAT team responded to the scene.
- When SWAT officers attempted to enter the house, Arriola fired additional shots from inside.
- Arriola was indicted for one count of first-degree murder and multiple counts of attempted murder, including attempted first-degree murder and attempted second-degree murder.
- Arriola was not found competent to stand trial until 2006.
- While in custody between 1995 and 2006, multiple doctors observed severe hallucinations and delusions and opined that, because of those symptoms, Arriola was unable to understand the wrongfulness of his conduct at the time of the shootings.
- Following a bench trial, the trial court rejected the insanity defense and convicted Arriola of first-degree murder, attempted first-degree murder, and two counts of attempted second-degree murder, imposing an effective sentence of life plus fifteen years.
- In an earlier appeal, the Court of Criminal Appeals remanded for clarification of the trial court’s findings regarding the insanity defense.
- On remand, the trial court issued a clarification order indicating that an understanding of an act’s wrongfulness was included within an understanding of the act’s nature.
- Arriola appealed again, arguing that the trial court used an incorrect legal standard for Tennessee’s statutory insanity defense and that the evidence proved insanity by clear and convincing evidence.

## Issues

1. Did the trial court apply an incorrect legal standard when it evaluated Arriola’s insanity defense by treating appreciation of wrongfulness as part of understanding the nature of the act?
2. If the correct standard is applied, did Arriola prove by clear and convincing evidence that he was not guilty by reason of insanity?

## Decision

- The Court of Criminal Appeals held that the trial court applied an improper legal standard in analyzing the insanity defense.
- The court explained that Tennessee’s statutory insanity defense requires a separate evaluation of whether, due to a severe mental disease or defect, the defendant lacked substantial capacity either to appreciate the wrongfulness of the conduct or to conform the conduct to the requirements of the law.
- The trial court’s clarification order reflected a mistaken approach by folding the “wrongfulness” inquiry into a “nature of the act” analysis.
- Because the convictions rested on an insanity analysis using an incorrect standard, the appellate court reversed the convictions.
- The case was remanded for a new trial.
- The appellate court did not enter a judgment of not guilty by reason of insanity; it left the insanity determination to be decided at the new trial under the correct legal test.

## Legal Principles

- In Tennessee, insanity is an affirmative defense that the defendant must prove by clear and convincing evidence.
- Under Tenn. Code Ann. § 39-11-501, a defendant is not criminally responsible if, at the time of the offense and as a result of a severe mental disease or defect, the defendant lacked substantial capacity either to appreciate the wrongfulness of the conduct or to conform the conduct to the requirements of the law.
- A defendant may understand what he is physically doing yet still be unable, because of mental illness, to appreciate that the conduct is wrong; those concepts are not interchangeable in applying the statutory test.
- When a trial court applies an incorrect legal standard to the insanity defense, reversal is warranted because the error affects the determination of criminal responsibility.
- Where the insanity analysis is legally flawed, the proper remedy is generally a new trial so the trier of fact can apply the correct standard to the evidence.

## Conclusion

State v. Arriola reversed a bench-trial conviction for first-degree murder and related attempted-murder offenses because the trial court evaluated the insanity defense under an incorrect legal standard, treating appreciation of wrongfulness as part of understanding the nature of the act; the Court of Criminal Appeals remanded for a new trial so the insanity defense could be assessed under Tennessee’s statutory test.


State v. Arriola, 2009 Tenn. Crim. App. LEXIS 728 (2009)