Polmatier v Russ
Citation: Polmatier v Russ, 537 A.2d 468 (Conn. 1988)
Parties:
- Dorothy Polmatier (plaintiff)
- Norman Russ (defendant)
Facts:
- Russ went to his father-in-law’s house and got in an argument with him, began beating him with a beer bottle, then grabbed a gun and shot him twice, killing him. About an hour later, he was found naked, holding his daughter in blood covered clothes with the murder weapon next to him. Russ was found to suffer from schizophrenia and declared mentally insane so he was found criminally not guilty of murder by reason of insanity. Russ first said he beat with a bottle and killed him because his father in law had a drinking problem and that he wanted to teach him a lesson, then later he said his father in law was a Chinese spy that would hurt him and his daughter so he killed him in self defense.
Procedural History:
- The trial court entered judgement for P, D appealed.
Issue:
- Was there an intent to contact when the alleged tortfeasor was mentally insane/suffering from schizophrenic delusions?
Rule:
- Intent means that the actor desires to cause consequences of his act, or he believes the consequences are substantially certain to result from it, but if actions are reflexive or the result of convulsions they are not considered intentional.
Holding:
- Yes, Russ did intend to contact his father in law because he voluntarily moved his muscles, regardless of his mental condition.
Reasoning:
- It doesn’t matter that he was insane, and unable to make a rational choice, his movement was not purely convulsive or reflexive so it counts as an act. Moreover, it doesn’t matter if someone’s thoughts motive for doing something is super irrational, if he still did the act itself on purpose that means there was intent. Here, Russ told police that when he was performing the subject actions, he indeed intended to beat and then shoot his father-in-law, but gave his mentally deranged reasons for believing it was justified. Because he confirmed that the movements themselves were voluntary, the intent element was established. It does not matter if his motives for forming the intent were irrational.
Decision:
- Affirmed
Disclaimer: This is not legal advice. This case brief and the others on this website are based solely on my personal understanding of the underlying case. They emphasize the points that my law professors emphasized. You should use them merely as a supplement to your own studies.