A Minnesota man charged with arson, burglary and theft attempted to assert a defense of mental illness but was denied the ability to. In State of Minnesota v. Tyson Joe Hinckley , filed May 1, the Minnesota Supreme Court reversed and remanded the case to district court, finding that the district court had abused its discretion.
Officers were alerted to garage fire in Lyon County in 2019. At the scene, officers discovered Tyson Hinckley, who was wearing only boxer shorts and was covered in mud and scratches. Hinckley claimed that a Lyon County Sheriff had tried to murder him and that he been pursued by police on a boat with guns.
Hinckley told law enforcement that he set the garage fire to help him escape law enforcement’s pursuit, and then stole a car from the garage to escape. He reported that he had spent the past night in a river hiding from police and left his clothes behind. Hinckley stated that he needed to speak with the FBI to get them to conduct the investigation instead of local law enforcement.
Subsequently, Hinckley was charged with first-degree arson, second-degree burglary, and motor vehicle theft. He moved the court to order a mental examination. The psychologist determined that, at the time of the offenses, Hinckley was mentally ill and that the mental illness caused his paranoid thoughts and delusions of persecution.
“At that point, he was not able to rationally acknowledge the wrongfulness of his act of setting fire in another person’s garage because his instincts to survive overrode his capacity for rational judgment,” the psychologist asserted.
The psychologist diagnosed Hinckley with alcohol use disorder, marijuana use disorder, paranoid personality disorder, persistent depressive disorder, post-traumatic stress disorder, and stimulant use disorder.
However, the state moved to deny assertion of the mental illness defense, arguing that Hinckley’s actions were motivated by voluntary methamphetamine use rather than mental illness. The court granted the state’s motion, finding that the psychologist was unclear about whether Hinckley’s actions were solely motivated by his mental illness or were partially caused by voluntary methamphetamine use.
Although the psychologist submitted two supplemental reports stated that Hinckley’s mental illness predated any drug use, and that voluntary intoxication was not the cause of Hinckley’s mental illness, the court rejected motions to reconsider the defense of mental illness.
Hinckley was found guilty on all three charges by the court. He was sentenced to 58 months in prison for first-degree arson. While he was found guilty of the other two charges, the executions of those sentences were stayed.
On appeal, Hinckley argued that he should have been able to assert the mental illness defense.
“The ruling was wrong, and it denied Hinckley his federal and state constitutional rights to present a mental illness defense,” Adam Lozeau, assistant state public defender, asserted.
Under Minnesota law, defendants are permitted to assert a mental illness defense under narrow circumstances: It requires proof that the actor suffered from a defect of reason, affecting him so that he did not understand that nature or wrongness of the action. This bifurcates the trial process, where the first part looks at whether elements of the offenses were proved beyond a reasonable doubt and, if so, the defendant’s mental state is evaluated. This evidence must meet a prima facie standard.
The state argued that the psychologist’s opinions and conclusions were not definitive, as there were inconsistencies and weaknesses.
“The defense’s evidence was the opinions of an expert who was noncommittal on his opinion and never clearly answered the pertinent question of whether or not Mr. Hinckley would have defect in reason even if he had not used the meth,” said Julianna Passe, assistant Lyon County attorney.
However, the court found that there was enough among the three reports to meet the prima facie standard.
“The district court is not wrong in noting some equivocation in the psychological reports, and the possibility of concurrent causation,” wrote Judge Barry Anderson, who authored the decision. “Even if the district court is correct that some of the reports submitted by Hinckley are unclear or contradictory on the issue of voluntary intoxication, Hinckley has more than adequately established a prima facie case of a mental-illness defense as required by the rule.”
Additionally, the court maintained that it could not conclude that the state showed that the jury’s verdict “was surely unattributable” to the error.
“The State has not proven that the error hereprecluding the jury from hearing Hinckley’s evidence about his mental illness and considering whether Hinckley’s criminal liability should be excused because of that mental illnesssurely had no impact on the verdict,” stated Anderson.
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