## Facts

- Roland Arthur Edwards entered a bank in Naples, Florida, passed a note demanding large bills, and warned the teller not to do anything.
- He carried a zipper bag containing a bulky L-shaped object, kept his hand inside, and handled the object so the teller believed it was a gun.
- Edwards fled with $2,040, ran to a pickup truck, and drove away.
- A bystander reported the name “Edwards Construction” on the vehicle.
- Deputies contacted Edwards’s ex-wife, who reached him by beeper; when Edwards returned the call, he admitted he had robbed a bank.
- Edwards was charged with unarmed bank robbery under 18 U.S.C. § 2113(a) and pleaded not guilty by reason of insanity.
- At trial, Edwards did not dispute committing the robbery’s physical acts; he relied on an insanity defense supported by lay witnesses and his treating psychiatrist, who suspected a manic-depressive illness at the time of the robbery.
- The government’s rebuttal psychiatrist testified that Edwards was not in an active manic state because his actions were “reasonably well controlled and goal directed,” and that financial stress and IRS debt provided an understandable motive.
- The jury convicted Edwards after a two-day trial.

## Issues

1. Whether Federal Rule of Evidence 704(b) was violated by allowing the government psychiatrist to testify in a manner that allegedly stated an opinion on the ultimate issue of Edwards’s sanity or criminal responsibility.

## Decision

- The Eleventh Circuit affirmed the conviction.
- The court held the district court did not err under Rule 704(b) in admitting the government psychiatrist’s testimony.
- The testimony was admissible because it described Edwards’s mental condition, behavior, and motivation without giving a legal conclusion on insanity or an ultimate mental-state element.

## Legal Principles

- Under Federal Rule of Evidence 704(b), an expert in a criminal case may not state an opinion or inference that the defendant did or did not have the mental state or condition constituting an element of the crime or of a defense (including legal insanity).
- Rule 704(b) does not bar expert testimony explaining diagnosis, symptoms, mental condition, behavioral characteristics, or motivation at the time of the act, so long as the expert does not provide a direct conclusion on the legal standard for criminal responsibility.
- Testimony that conduct appeared controlled, purposeful, or consistent (or inconsistent) with a particular psychiatric condition may be admissible when framed as clinical assessment rather than a statement that the defendant was legally sane or insane.
- The trier of fact retains responsibility to decide the ultimate legal issue of sanity after weighing competing expert testimony.

## Conclusion

The court upheld Edwards’s bank-robbery conviction, ruling that Rule 704(b) permits psychiatric experts to describe clinical observations and explain whether conduct is consistent with a claimed mental disorder, but forbids experts from telling the jury the defendant was legally insane or otherwise lacked the ultimate mental state required for criminal responsibility.


United States v. Edwards, 819 F.2d 262 (11th Cir. 1987)