Ladies and gentlemen of the jury, let’s review the legal standard for insanity in this state. The standard is: Did the mental illness affect the defendant’s ability to perceive the nature and quality of his actions, or was he unable to tell the difference between right and wrong?
The evidence is such that you must answer this question in the affirmative. And this result is compelled not only by the science of psychiatry, but also by simple common sense. But lets talk about psychiatry first. What did the experts say? They all agreed, even the state’s expert, that my client has suffered from the disease of paranoid schizophrenia. That is agreed. They all agreed he was not malingering this disease, they all agreed he had it since childhood, and they even all agreed that this disease affected his behavior on the day in question. This is agreed. This wasn’t something he cooked up after the fact because it was convenient, or that he was coached into claiming. This is the simple truth of the matter, it is the simple, cold, hard fact of this case. And that is what trials are about: the truth, and facts. We see this schizophrenia when he is kicked out of college, we see it when he was rejected from the military, and we see it when he awarded permanent, 100% disability. And we saw it on May 1st, didn’t we. We saw it when he complained to the police that Mr. Anderson was the devil and was trying to kill him. We saw it when he was in his slippers and bathrobe walking in 6 inches of snow, walking up the steps to Mr. Anderson’s house. And we saw it when he bludgeoned that poor man to death. And this is very disturbing. We know it was for you. But this action was committed because my client had no idea what he was doing and thought Mr. Anderson was the devil. And that, ladies and gentlemen, is insanity. Pure and simple.
He had no motive to kill Mr. Anderson. Mr. Anderson was just another man from his store, we don’t know why he obsessed over the man, and we probable never will. We have the insanity law for a reason. If you don’t apply it here, then when would you ever apply it? My client is sick, and it is hard for me to say that, but that is what he is, sick, sick with schizophrenia, and we don’t put sick people in a jail, we put them in hospitals, and that is where he belongs in a mental hospital, not a prison.
The state argues that my client is using this as an excuse. Tell me, if he wanted to get away with murder, couldn’t he have done that? Mr. Anderson lives alone, in an isolated area. Couldn’t he have just snuck in at night? No, instead he walked up in broad daylight, he wasn’t acting to hide anything. Does the state really think that this was all part of a plan? Really? Remember that my client shared his paranoid delusions about Mr. Anderson with everybody who would listen. Is that really what a sane man does when he is planning on committing a murder months later? The answer is no. The verdict should be not guilty.
Here is the prosecutor's response:
Ladies and gentlemen, before you incorrectly conclude that Mr. Jacobs was stark raving mad, let remember some of the facts to keep this in perspective. This is a man who, though unemployed, did live a functioning life. He had friends, he had an on-and-off relationship with a woman, this is a man who did his own shopping, and managed his own money. He took planned and deliberate actions everyday. And in the end, he knew what he was doing when he went to Mr. Anderson’s house that night.
Remember that just because someone is mentally ill, that doesn’t make them insane. That is an important point. Almost by definition, the life of a murderer is chaotic, they are disturbed, and it never makes sense, it never makes sense to take a human life. Never. You don’t get a free pass simply because you are crazy. You don’t.
Contrary to what defense counsel says, Mr. Jacobs did know what he was doing. He did. Where was the gun when he walked up to Mr. Anderson’s home? It was hidden. It was hidden under his bathrobe. He knew what would happen if people saw what he was doing. He knew that what we was doing was wrong. He knew that he would be stopped, that he would be arrested if they saw the gun. A bathrobe and slippers in the snow? Yeah, that is weird. That is eccentric. A lot of people are eccentric. It doesn’t make them insane. It doesn’t. Walking up to commit murder in a bathrobe and slippers shows the impulsiveness of the action. That he was so intent on killing Mr. Anderson that he couldn’t bother to get dressed first. That is impulsive. It is a rash, its is hot-blooded, but it is not insanity.
It is true that we don’t know the motive for the offense. Well, under the law, the state doesn’t have to prove motive. That means the law says the prosecutor doesn’t have to read people’s minds. And in case you didn’t notice, Mr. Anderson isn’t around to tell us the background of his dealings with Mr. Jacobs.
In this case, the defense has to prove insanity by a preponderance of the evidence. It is not the prosecutor’s job to prove he was sane. We only have to prove that he intentionally killed someone without lawful excuse. And we have done that. The correct verdict is guilty on the charge of murder in the first degree. Thank you.
