## Facts

- Mark Taylor was indicted in federal court on five counts of carjacking.
- At trial, the government presented evidence that Taylor carjacked multiple victims and raped them during the course of the offenses.
- After raping one victim, Taylor destroyed evidence that could implicate him and warned the victim not to call the police.
- After raping another victim, Taylor wiped down everything he had touched to avoid detection.
- The evidence also showed Taylor choked a victim to prevent others from hearing her screams.
- After his arrest, Taylor attempted to trick police into believing someone else carjacked and raped one of the victims.
- Taylor raised an insanity defense based on asserted post-traumatic stress disorder (PTSD).
- Dr. Joseph Angelillo, a clinical psychologist, testified that Taylor had PTSD and that it could affect Taylor’s ability to appreciate the wrongful nature of his crimes.
- Dr. Rodolpho Buigas, a forensic psychologist, disputed that Taylor had PTSD and testified that, even if Taylor had PTSD, it would not affect Taylor’s ability to appreciate the wrongful nature of his crimes.
- The jury convicted Taylor on all five carjacking counts.

## Issues

1. Did the district court err in rejecting Taylor’s insanity defense, given the competing psychological testimony and evidence of Taylor’s conduct during and after the offenses?

## Decision

- The Sixth Circuit affirmed the judgment of conviction.
- The court upheld the rejection of Taylor’s insanity defense.

## Legal Principles

- Federal insanity is an affirmative defense governed by 18 U.S.C. § 17.
- The defendant bears the burden to prove insanity by clear and convincing evidence.
- Under § 17, it is not enough to show a mental-health diagnosis; the defendant must show that, because of a severe mental disease or defect, he was unable to appreciate the nature and quality or wrongfulness of his acts at the time of the offenses.
- When expert testimony conflicts, the factfinder may credit one expert over another; an appellate court does not reweigh credibility determinations as if trying the case anew.
- Evidence that a defendant destroyed evidence, wiped surfaces, warned a victim not to contact police, choked a victim to silence her, or attempted to mislead investigators can support a finding that the defendant appreciated the wrongfulness of his conduct, defeating an insanity claim.

## Conclusion

In *United States v. Taylor*, the Sixth Circuit affirmed Taylor’s five carjacking convictions, concluding that the record—including competing expert testimony regarding PTSD and substantial evidence that Taylor took deliberate steps to avoid detection and mislead law enforcement—supported the district court’s rejection of Taylor’s insanity defense under 18 U.S.C. § 17.


United States v. Taylor, 483 Fed. Appx. 992 (2012)