## Facts

- Walter J. Sikora shot and killed Douglas Hooey on January 15, 1962, after being taunted and assaulted at a bar.
- After the incident, Sikora reported the assault to police, went home, retrieved a handgun, test-fired it, returned to the bar, and shot Hooey four times.
- Witnesses described Sikora as acting in an “automated” manner.
- Sikora then went to a woman’s home intending to kill her, but she was not present; he was arrested thereafter.
- Sikora’s defense centered on psychiatric evidence tied to his childhood trauma and long-term emotional disturbance.
- He did not claim legal insanity under the M’Naghten test; he conceded he knew what he was doing and that it was wrong.
- The defense sought expert testimony that Sikora’s mental and emotional condition made him incapable of premeditation and deliberation because the killing resulted from compulsive, automatic action.
- The trial court excluded the proffered psychiatric testimony.
- A jury convicted Sikora of first-degree murder and recommended life imprisonment; the court imposed a life sentence.

## Issues

1. Whether the trial court abused its discretion by denying Sikora’s motions for mistrial.
2. Whether, in a first-degree murder prosecution where the defendant concedes legal sanity, psychiatric testimony is admissible to show incapacity to premeditate and deliberate, thereby negating the mental elements distinguishing first-degree murder.

## Decision

- The Supreme Court of New Jersey affirmed the conviction and life sentence.
- The Court found no reversible error in the denial of the mistrial motions, treating the decision as discretionary and not arbitrary on this record.
- The Court held the trial court properly excluded the psychiatric testimony offered to negate premeditation and deliberation where the defendant did not claim legal insanity.

## Legal Principles

- Granting or denying a mistrial lies largely within the trial court’s discretion; appellate relief requires a showing that the ruling was arbitrary or lacked support in the record.
- Under New Jersey law, the insanity defense is governed by the M’Naghten standard (lack of knowledge of the nature and quality of the act or that it was wrong).
- Psychiatric evidence of mental abnormality, personality defect, emotional disturbance, or compulsive tendencies short of legal insanity is not admissible to negate premeditation and deliberation for purposes of reducing first-degree murder.
- Recognition of any partial-responsibility doctrine allowing sub-insanity conditions to negate elements of first-degree murder is for legislative action, not judicial creation.

## Conclusion

The court upheld Sikora’s first-degree murder conviction, ruling that because he did not assert legal insanity, he could not introduce psychiatric testimony to show he lacked the capacity to premeditate and deliberate, and the trial court’s denial of mistrial motions was within its discretion.


State v. Sikora, 44 N.J. 453, 210 A.2d 193 (N.J. 1965)