State v. Nataluk

N.J.S.A. 2C:4-2 (“Evidence that the defendant suffered from a mental disease or defect is admissible whenever it is relevant to prove that the defendant did not have a state of mind which is an element of the offense.”)

John Frank Nataluk was convicted on multiple criminal charges related to firing a weapon into an unoccupied store. At trial, he presented an unsuccessful insanity defense supported by psychiatric testimony. On appeal, Nataluk argued that the jury should have been asked to consider whether he had a “mental disease or defect” which resulted in his lacking the requisite state of mind to be found guilty of the charged offenses.

A mental condition must be considered as a mitigating factor even if the jury rejected an insanity defense. Moreover, all mental deficiencies, including conditions that cause a loss of emotional control, may establish diminished capacity if there is sufficient evidence to indicate that (1) the mental deficiency can affect cognitive faculties; and (2) the deficiency did affect the person’s cognitive capacity to form the necessary mental state.

According to the Court, the principle of diminished capacity in N.J.S.A. 2C:4-2 “bears some resemblance to an insanity defense, but the two are distinguishable.” The court emphasized that it is the state, not the defendant, who must prove the requisite state of mind. If there is reasonable doubt as to whether a person’s mental condition allowed them to form the state of mind that is an essential element of the crime, an acquittal is appropriate. The court clarified that not every mental condition qualifies as diminished capacity under the statute, but must be one that pertains to the “existence or nonexistence of a state of mind prescribed by the code.” For example, “uncontrollable rage or lack of control would not, by itself, negate a requisite mental condition such as knowledge or purpose.”

But the Court rejected a formal “impenetrable line” between conditions that affect cognition and those affecting impulse or emotional control. “[M]erely because a particular mental condition may cause a loss of emotional control does not mean that it could not also affect a person’s cognitive faculties so as to negate the existence of a requisite mental condition.” According to the court, the key principle for diminished capacity is “whether the mental condition affects cognitive capacity sufficient to preclude the necessary mental state.”