## Facts

- John Robert Taylor was a convicted felon with a reported history of schizophrenia diagnoses and long-term severe alcohol abuse.
- On April 3, 2015, a police officer attempted to arrest Taylor for public intoxication.
- During the encounter, Taylor attempted to fire a gun at the police officer.
- While being arrested, Taylor threw the gun into a vehicle parked nearby.
- Taylor was charged with being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).
- Taylor provided notice that he intended to plead not guilty by reason of insanity under 18 U.S.C. § 17, relying on schizophrenia and alcohol abuse.
- A court-appointed psychologist evaluated Taylor and could not conclusively determine whether Taylor suffered from a severe mental disease or defect that prevented him from understanding the nature of his offense at the time of the incident.
- The psychologist noted Taylor had not received treatment for schizophrenia for about 20 years and concluded Taylor’s actions were primarily caused by long-term severe alcohol abuse.
- The psychologist characterized alcoholism as a substance-use disorder recognized as a chronic illness in the medical community.
- A friend testified that in the days before the incident Taylor talked to himself and acted unusually.
- Taylor did not present evidence establishing his specific level of intoxication at the time of the incident.
- The government opposed the insanity defense, relying in part on Poolaw v. United States to argue that alcoholism is not a “severe mental disease or defect” for purposes of § 17.

## Issues

1. Whether chronic alcoholism, even if recognized medically as a substance-use disorder, can qualify as a “severe mental disease or defect” under 18 U.S.C. § 17 to support a federal insanity defense.
2. Whether Taylor produced clear and convincing evidence that, as a result of a qualifying severe mental disease or defect, he was unable to appreciate the nature and quality or wrongfulness of his acts at the time of the firearm-related conduct.

## Decision

- The court rejected Taylor’s insanity defense under 18 U.S.C. § 17 on the record presented.
- The court concluded Taylor failed to prove by clear and convincing evidence that he had a qualifying severe mental disease or defect that rendered him unable to appreciate the nature and quality or wrongfulness of his acts at the time of the offense.
- The court determined the evidence primarily attributed Taylor’s conduct to long-term severe alcohol abuse rather than to an active, qualifying psychotic disorder meeting § 17’s standard.

## Legal Principles

- Under 18 U.S.C. § 17(a), a defendant is not responsible for criminal conduct only if, at the time of the offense, and as a result of a severe mental disease or defect, the defendant was unable to appreciate the nature and quality or wrongfulness of his acts.
- Insanity is an affirmative defense, and 18 U.S.C. § 17(b) places on the defendant the burden to prove it by clear and convincing evidence.
- A medically recognized diagnosis (including a substance-use disorder) does not automatically satisfy the legal requirement of a “severe mental disease or defect” under § 17.
- Voluntary intoxication or alcohol abuse, without proof of the statutory incapacity caused by a qualifying severe mental disease or defect, does not establish a federal insanity defense.
- Evidence must connect the claimed qualifying condition to the defendant’s inability to appreciate the nature and quality or wrongfulness of the acts at the time of the charged conduct; equivocal expert opinions and general lay observations are not enough to meet the clear-and-convincing standard.

## Conclusion

United States v. Taylor held that Taylor could not proceed with a federal insanity defense where the evaluation evidence did not clearly and convincingly show that a qualifying severe mental disease or defect—rather than long-term alcohol abuse—made him unable to appreciate the nature and quality or wrongfulness of his conduct during the incident that led to the § 922(g)(1) charge.


United States v. Taylor, 224 F. Supp. 3d 1262 (2016)