## Facts

- Felix Garcia, a convicted felon, was prosecuted in federal court for possessing a firearm in violation of 18 U.S.C. § 922(g)(1).
- During the incident underlying the charge, Garcia confronted a police officer with a gun.
- Garcia had a history of mental disorders and substance abuse and was intoxicated at the time of the offense.
- Garcia asserted the federal insanity defense under 18 U.S.C. § 17 (Insanity Defense Reform Act).
- Defense expert testimony attributed Garcia’s conduct mainly to mental disorders.
- Government expert testimony attributed Garcia’s conduct primarily to drugs and alcohol.
- The district court instructed the jury that the insanity defense applied only if mental disease or defect, rather than substance abuse, was solely responsible for any inability to appreciate the nature, quality, or wrongfulness of the act.
- The jury rejected the insanity defense and convicted Garcia.

## Issues

1. Whether, under 18 U.S.C. § 17(a), the district court erred by instructing that a defendant can be found insane only if severe mental disease or defect is the sole cause of the inability to appreciate the nature, quality, or wrongfulness of the acts, excluding any role for voluntary intoxication.
2. Whether any instructional error was harmless given the parties’ competing expert theories about mental illness versus intoxication as the cause of Garcia’s conduct.

## Decision

- The Second Circuit vacated the conviction and remanded for a new trial.
- The court held the insanity instruction misstated 18 U.S.C. § 17(a) by imposing a “sole cause” requirement not found in the statute.
- The court concluded the error was not harmless because the instruction foreclosed a material defense theory supported by evidence: that severe mental disease or defect could render Garcia unable to appreciate wrongfulness even if intoxication was also present.

## Legal Principles

- Under 18 U.S.C. § 17(a), the insanity defense requires proof that, at the time of the offense, the defendant was unable to appreciate the nature and quality or wrongfulness of the acts as a result of a severe mental disease or defect.
- The statute does not require that severe mental disease or defect be the exclusive cause of the incapacity; multiple contributing causes may exist so long as the statutory mental disease or defect is a legally sufficient cause.
- Voluntary intoxication alone cannot establish federal insanity, but intoxication does not automatically bar the defense where a qualifying severe mental disease or defect substantially causes the inability to appreciate wrongfulness.
- A jury instruction is erroneous if it prevents the jury from considering whether severe mental disease or defect, even intertwined with substance abuse, satisfies § 17(a)’s causation requirement.

## Conclusion

The Second Circuit ordered a new trial because the jury was incorrectly instructed that insanity required mental disease or defect to be the sole cause of Garcia’s incapacity, improperly excluding the possibility that severe mental illness could satisfy 18 U.S.C. § 17(a) even when voluntary intoxication also contributed.


United States v. Garcia, 94 F.3d 57 (2d Cir. 1996)