State v. Guido
40 N.J. 191, 191 A.2d 45 (1963)

  • Guido was married to a boxer who was occasionally abusive. She asked for a divorce but he threatened her. Despondent, Guido got a gun and considered suicide. But instead she shot her husband multiple times while he was sleeping.
  • Guido was arrested and charged with first-degree murder. She confessed, but pled not guilty by reason of insanity.
    • Guido was interviewed by some psychiatrists hired by her attorneys.
    • The psychiatrists originally found that Guido was legally sane, but after talking to the defense attorney about the legal definition of insanity, they changed their conclusions.
      • Under the common-law, an insanity defense requires that the defendant suffer from a ‘disease of the mind’, which the psychiatrists assumed did not include ‘anxiety neurosis’. After being reassured by the defense attorney that it did, they changed their opinions.
  • At Trial, the prosecutor found out that the psychiatrists had changed their report, and accused them of faking their results.
  • The Trial Court found Guido guilty of first-degree murder. She appealed.
    • Guido argued that the prosecutor’s statements unfairly biased the jury.
  • The New Jersey Supreme Court overturned the conviction and remanded for a new trial.
    • The New Jersey Supreme Court found that Guido did not commit fraud when her defense attorney changed the psychiatrists’ understanding of the legal definition of insanity.
      • The Court noted that there is no good legal definition of what is meant by a ‘disease of the mind.’
    • The Court found that the prosecutor’s accusations unfairly biased the jury.
  • Different jurisdictions define the term ‘disease of the mind’ differently.
    • For example, McDonald v. United States (312 F.2d 847 (1962)) defined a ‘disease of the mind’ as “any abnormal condition of the mind which substantially affects mental of emotional processes and substantially impairs behavioral controls.”