In a decision that further enshrines a traditional test for insanity, the court held that the insanity defense against punitive damages in a civil trial must satisfy the same test as the defense in a criminal case.
The perpetrator at the time of this appeal was a ward represented by his wife as guardian.
The defendant, Edwards, had harbored a paranoid delusion that Stills was having an affair with his wife and stealing from him. His flights of thought, however, ranged far beyond ruminations about treachery; they also encompassed plans for murder.
First Edwards abducted Stills at gunpoint forcing him to drive home, all the while threatening to shoot him. After entering Still's basement, Edwards tied him so tightly that he was immobilized and his hands started to turn blue. He then tormented Stills with repeated threats about an excruciating death accompanied by demonstrations with butcher knives and the corrosive effects of muriatic acid poured on stonework He threatened to splatter acid in Stills' face and eyes. Stills ultimately escaped when Edwards inexplicably left the house.
At the conclusion of the ensuing tort action brought by the victim and his wife against Edwards, the plaintiffs were awarded $243,600 in compensatory damages and $1,500,000 in punitive damages.
Edwards appealed whether the lower court correctly assessed punitive damages against a party who was psychotic and delusional at the time and so, it was claimed, could not form the requisite intent (malice, wanton indifference) necessary for a finding that punitive damages are appropriate.
The Appellant argued that the proper test is an individual determination as to whether the defendant suffered from mental disease or defect.
The court rejected that argument, ruling that the criminal standard, "whether the person lacked capacity to conform his conduct to the requirements of the law or appreciate the criminality of his conduct," also applies to civil punitive damages.
The evidence established both planning and attempts at concealment on the part of Edwards. He was clearly mentally ill, but still sufficiently competent to justify the court's award of further damages.
WHAT STILLS MEANS
Sued for damages, a civil defendant must satisfy the same criteria as the criminal defendant in order to apply the defense of insanity.
