United States v. Freeman
United States Court of Appeals for the Eleventh Circuit
804 F.2d 1574 (1986)

- Written by Kelli Lanski, JD
Facts
Dwayne Freeman (defendant) volunteered for a charity that raised money for children in Ethiopia. He became upset about failing to fundraise enough money and robbed a bank, allegedly to contribute to the charity’s funds. Freeman used a mask, handgun, and satchel to execute the robbery and told bank employees he would return and kill them if they called police. When police spotted him after the robbery, Freeman ran away and changed his clothes to avoid detection. Freeman was arrested, and a prison psychiatrist determined that he was suffering from severe mental illness. Freeman pled not guilty by reason of insanity but was convicted. He appealed, arguing that the definition of insanity in the Insanity Defense Reform Act of 1984 (IDRA) violated his constitutional rights. The IDRA’s definition of insanity as applied to the insanity defense covered individuals who were unable to appreciate the wrongfulness of their acts. It did not excuse from criminal culpability individuals who knew right from wrong but claimed they could not conform their conduct to the requirements of the law. Freeman argued that punishing him when he could not conform his conduct to the law violated the Eighth Amendment’s prohibition against cruel and unusual punishment.
Rule of Law
Issue
Holding and Reasoning (Hill, J.)
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