Fourth Department – Mental illness: People v. Williams

New York State Supreme Court, Appellate Division, Fourth Judicial Department

Mental illness — Affirmative defense — Relevance

People v. Williams

KA 22-01414

Appealed from Supreme Court, Monroe County

Background: The defendant appealed from his conviction of attempted aggravated murder, attempted murder, aggravated assault upon a police officer, and assault. The conviction arose from an incident in which officers were called to remove the defendant from the residence due to his abnormal behavior and mental health concerns. A responding police officer coaxed the defendant out from under a bed, but the defendant attacked without warning with a knife. On appeal, he argues the court erred by granting the people’s motion to preclude the defendant’s proposed psychiatric witness.

Ruling: The Appellate Division reversed. The court noted that the defendant provided the people with timely and sufficient notice of his intent to offer psychiatric evidence. The defendant argued the psychiatrist’s testimony and post-crime diagnosis was not for the affirmative defense sought but rather the mental disease or defect element of that defense. The Appellate Division held that the testimony was relevant even though he examined the defendant over a year after the incident as he had reviewed the defendant’s medical history.

Gregory Salmon, of Criminal Appeals Advocates, for the defendant-appellant; Lisa Gray, of the district attorney’s office, for the respondent.

Oral argument video