The state Supreme Court upheld the conviction Friday of a woman who stabbed her niece to death, issuing a ruling that the court’s lone dissenter said overturns 40 years of law allowing juries to consider a defendant’s mental state.
The Vermont Supreme Court ruled that the trial judge was correct to instruct the jury considering the case against Latonia Congress of Essex Junction not to consider the woman’s mental capacity when the crime took place.
The case stems from the 2009 killing of Shatavia “CeCe” Alford, a 16-year-old Essex High School student, by Congress in their home on Park Street. Congress’ attorneys had argued her mental capacity had been diminished by a long history of abuse. They asked the judge to tell the jury it could consider convicting her of voluntary manslaughter.
Congress was convicted in 2011 of second-degree murder. She is serving a sentence of 20 years to life in prison.
In its 4-1 decision, the court said it was reconciling different aspects of how Vermont law has used “diminished capacity” evidence in homicide prosecutions.
“We conclude that the trial court correctly declined to instruct the jury that it could consider the evidence of defendant’s psychological condition as a basis for convicting her of voluntary manslaughter,” said the majority decision written by Justice Beth Robinson.
But in his dissent, Chief Justice Paul Reiber said the majority was overturning long-held precedent that entrusted juries with the discretion to reduce murder to manslaughter based on evidence of a defendant’s diminished capacity.
“Today’s decision to abandon the settled defense of diminished capacity defies common sense, reason and authority,” Reiber wrote.
“Although our descriptions of the doctrine have not always been consistent, our commitment to its intrinsic justice has never wavered. This is because, like all good common-law principles, its source does not lie in case books — but in the human heart. The law is diminished if we forget this.”
The 12,000-word decision and dissent provides a detailed history of the evolution of Vermont’s homicide laws.
David Sleigh, a defense attorney who was not involved in the Congress case, said Vermont law has historically allowed juries to “look at the human condition” when considering issues such as diminished capacity in homicide cases.
“Justice Robinson and the majority are continuing the progression to analytical law away from a visceral jury reaction,” Sleigh said.
He didn’t know how much impact the ruling would have on future cases.
Assistant Attorney General John Treadwell, the head of the criminal division, said they had been waiting for the decision, which was argued in February 2013.
“There has been something of a lack of clarity regarding the issue of diminished capacity,” Treadwell said.
“It’s a complicated area, the issue of mental state,” he said.
— The Associated Press