State v. Brom

Facts

The parents and siblings of David Brom (Defendant) were found dead in their home with numerous gash wounds. The ax used in the slayings was found in the basement of the house with Defendant’s fingerprints on the handle. Defendant was charged with murder in connection with the deaths of his parents and siblings. Defendant pleaded both not guilty and not guilty by reason of insanity, and Defendant’s trial was bifurcated pursuant to Minnesota law. The first phase of the trial was the guilt phase. During this phase, Defendant wished to introduce expert psychiatric testimony to prove that he was incapable of premeditation. The trial court ruled the testimony inadmissible and instructed the jury not to consider evidence of Defendant’s mental illness during the guilt phase. The jury found Defendant guilty of four counts of first-degree murder. During the second phase of the trial, or the insanity phase, the burden was on Defendant to prove his mental illness by a preponderance of the evidence. Defendant presented expert testimony from four psychiatrists, two of whom concluded that Defendant was not legally insane at the time of the murders. All of the experts, however, agreed that Defendant suffered from some form of mental impairment. The jury found Defendant guilty of all four counts of first-degree murder, and the court imposed four life sentences. Defendant appealed, arguing that the court had violated his due process rights in refusing to admit expert psychiatric testimony on the issue of premeditation in the guilt phase of the trial.