## Facts

- Larry Richard Jones was charged with second-degree assault while armed with a firearm after a late-night confrontation on the University of Washington campus with Officer Leif Granrud, who was in plain clothes and an unmarked car.
- During the encounter, Jones drew a pistol, a struggle occurred, and two shots were fired; no one was injured.
- Jones testified he drew the gun because Granrud did not identify himself as a police officer and appeared to reach toward a gun; Jones claimed he intended only to detain Granrud and the gun discharged accidentally.
- Granrud admitted he did not identify himself but denied reaching for his weapon; he testified Jones threatened him and cocked the gun while threatening to shoot.
- After Jones made unusual statements, the court ordered competency and mental-health evaluations; psychiatrists concluded Jones was competent to stand trial but suffered from paranoid schizophrenia and was legally insane at the time of the offense.
- The trial court found Jones competent yet, over his objection, granted the State’s motion to enter a not-guilty-by-reason-of-insanity (NGI) plea, appointing amicus counsel to present insanity while Jones pursued self-defense under a not-guilty plea.
- The jury was instructed on both defenses, found Jones committed the charged acts but was insane at the time, and returned an NGI verdict; the court ordered commitment despite a jury recommendation for less restrictive treatment.
- The Court of Appeals affirmed; Jones obtained review in the Washington Supreme Court.

## Issues

1. Whether a trial court may enter an NGI plea over the objection of a defendant found competent to stand trial.
2. What obligation a trial court has to confirm that a competent defendant’s decision to forgo an insanity defense is intelligent and voluntary.
3. Whether forcing an NGI plea in these circumstances is prejudicial error requiring a new trial.

## Decision

- The Washington Supreme Court reversed and remanded for a new trial.
- The court held that, where a defendant is competent to stand trial, a court may “rarely, if ever,” impose an NGI plea over the defendant’s objection.
- The court held the trial court must ensure any waiver of an NGI plea by a competent defendant is intelligent and voluntary.
- Imposing the NGI plea on Jones despite a competency finding was error, and the error was prejudicial because it altered the defense presented to the jury and led to an NGI verdict and commitment.

## Legal Principles

- Competence to stand trial is distinct from insanity at the time of the offense; evidence supporting insanity does not, by itself, justify overriding a competent defendant’s choice of defense.
- A competent defendant generally controls the objectives of the defense, including whether to assert or reject an insanity defense.
- Trial courts must make an adequate on-the-record inquiry to confirm that a competent defendant’s waiver of an insanity defense is intelligent and voluntary, including understanding the nature of the defense and the likely consequences of an NGI verdict (such as commitment).
- Judicial concern that insanity evidence is strong or that conviction is likely without an insanity defense is not a sufficient basis to impose an NGI plea on a competent defendant.
- Forcing an NGI plea against a competent defendant’s wishes can be prejudicial when it changes the character of the trial and channels the outcome toward an insanity verdict and consequent confinement.

## Conclusion

The court held that a competent defendant’s decision to reject an insanity defense must generally be respected, subject to a trial court’s duty to ensure the waiver is intelligent and voluntary; because the trial court forced an NGI plea on a competent defendant and that action affected the verdict and commitment, the judgment was reversed and the case remanded for a new trial.


State v. Jones, 99 Wash. 2d 735 (Wash. 1983)