United States v. Staggs Case Brief

Summary of United States v. Staggs, 553 F.2d 1073 (1977)

Facts: Df was wanted for desertion of the U.S. Marine Corps. The FBI located him in Illinois in an apartment with his wife. She let the FBI agents inside. One agent testified that Staggs hid behind the door with a gun and threatened to shot him, the other that the Df was going to shoot himself. Staggs testified that he threatened to shoot himself rather than return to the Marines.

Issue: Whether the trial court committed reversible error by excluding the testimony of a psychologist who examined the Df, who offered testimony that the Df would more likely hurt himself than others, in obtaining a conviction for assaulting a federal officer with a deadly weapon?

Holding: Yes.

Procedure: Conviction and sentenced as a youthful offender to an indefinite term. 7th Cir. Reversed and Remanded for new trial.

Rule: Relevant evidence is defined by FRE 401 as “evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence."

Rationale: A determination of the role the df’s mental state plays in the prosecution for assaulting a federal officer with a deadly weapon. If it is a general intent crime then the govt would not need to prove anything about the df’s state of mind. If the crime is a specific intent crime, the govt would need to prove that the df subjectively intended to put the federal officer in apprehension of bodily harm. The statute provides no clue whether specific or general. U.S. v. Feolaestablished that specific intent to commit assault is a prerequisite to conviction under the law the df was convicted. Therefore, the df should not have been convicted unless the govt demonstrated beyond a reasonable doubt that the Df subjectively intended to put the agent in apprehension of bodily harm, and the Dr’s testimony, as an expert, was relevant to the Df’s theory.

Pl A: The Dr’s proffered testimony is of questionable relevance and probative value, and introduction of expert testimony related to mental disease, defect, or other condition bearing on the mental state requires notice.

Df A: Under FRE 401 the Df’s testimony is relevant because the crime is a specific intent crime and the testimony bears on whether the crime was more likely than not, committed.

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