## Facts

- James Murphy was charged by information with first-degree murder, alleging he killed Robert Jack Blair during the commission or attempted commission of a robbery, including allegations that Blair was struck with a softball bat and shot with a .25-caliber pistol.
- Murphy entered a plea of not guilty and also filed a special plea of not guilty by reason of insanity, placing his mental condition in issue.
- Based on Murphy’s conduct and the insanity plea, the superior court ordered Murphy committed to a state hospital for observation and examination to determine his mental condition for purposes of the criminal case.
- Medical witnesses who examined Murphy during the ordered observation later testified at trial concerning Murphy’s mental state.
- Murphy was described as a nervous, frenetic person with a tense demeanor who had difficulty controlling his emotions even under ordinary conditions.
- On the morning Murphy was scheduled to testify, he told a fellow prisoner (a “medical trusty” for the prison doctor) that he had a severe cold.
- The fellow prisoner gave Murphy tranquilizer drugs. Murphy had not taken the drugs before and did not understand their effects.
- While testifying under the influence of the drugs, Murphy appeared abnormally calm for him in demeanor, appearance, and speech, and was unusually casual and laid back.
- The jury found Murphy guilty of first-degree murder and fixed the penalty at death.
- Murphy appealed, arguing that (among other claimed errors) the court-ordered psychiatric confinement and examination were unlawful and that his drug-altered demeanor while testifying may have affected the jury’s decision to impose the death penalty.

## Issues

1. Whether the trial court lawfully ordered Murphy committed for psychiatric observation and examination after his insanity plea, and whether testimony derived from that examination was properly admitted at trial.
2. Whether Murphy was denied a fair trial (or fair penalty determination) because tranquilizers given to him before he testified allegedly changed his courtroom demeanor in a way that could have influenced the jury to impose the death penalty.

## Decision

- The Washington Supreme Court affirmed the judgment and sentence.
- The court held that the statutory procedure allowing a court to order psychiatric observation and examination when sanity is in question authorized Murphy’s confinement for evaluation and did not violate due process.
- The court upheld admission of psychiatric testimony stemming from the ordered examination, rejecting claims that its use was improper where Murphy’s mental condition was placed in issue by his special plea.
- The court rejected Murphy’s claim that his tranquilizer-affected demeanor on the witness stand required reversal, concluding that the record did not justify disturbing the verdict and death sentence on that basis.

## Legal Principles

- When a defendant’s sanity or mental responsibility is put in issue, Washington law permits the trial court to order confinement for psychiatric observation and examination for purposes of the pending criminal proceeding.
- Psychiatric opinions based on a court-ordered examination may be admitted to assist the trier of fact on the sanity issue, and use of such testimony is not barred merely because the examination was ordered over the defendant’s objection when the defendant has placed mental condition at issue.
- A claim that medication affected a defendant’s courtroom demeanor does not, without a sufficient showing of resulting unfairness on the record, require reversal of a conviction or death sentence.

## Conclusion

In *State v. Murphy*, the Washington Supreme Court affirmed Murphy’s first-degree murder conviction and death sentence, holding that the trial court acted within statutory authority in ordering psychiatric observation after Murphy pleaded insanity, that resulting medical testimony was admissible, and that the defendant’s tranquilizer-altered demeanor while testifying did not warrant reversal on the record presented.


State v. Murphy, 355 P.2d 323 (1960)