STATE v. CURTIS BOWMAN, SC 17699
Judicial District of New Haven
Criminal; Whether Jury was Properly Instructed on Defense of Extreme Emotional Disturbance; Whether Photographs of Victim's Injuries Were Properly Admitted. The defendant was charged with murder and other crimes in connection with the killing of his girlfriend. The defendant, who had been diagnosed as suffering from psychosis, raised the affirmative defense of extreme emotional disturbance at trial. The jury rejected the defense and the defendant was convicted of murder. On appeal, he claims that the trial court improperly instructed the jury that, for purposes of the extreme emotional disturbance defense, it had to find that he suffered an "extreme" emotional reaction and that his reaction was "the greatest degree of intensity away from his normal state." The defendant claims that, because his mental illness causes his "normal state" to be more emotionally volatile than that of a person without his disability, the instruction was improper in that it allowed the jury to reject his defense if it found that his emotional state during the commission of the crime did not greatly vary from his usual state of agitation. As a result, he contends that he was deprived of his defense because he was unfairly held to a standard that differs from that which would be applied to a person who is not mentally ill. He thus claims a violation of his rights to equal protection and a fair trial and of his special protection as a mentally disabled person under the state constitution. In addition to the foregoing, the defendant argues that he was prejudiced by the admission of eight gruesome photographs of the victim and that the trial court improperly instructed the jury on reasonable doubt.