Robinson v. State
Robinson v. State
Opinion of the Court
Following a bench trial on a charge of bus hijacking, Jeffrey Donta Robinson was found guilty but mentally ill. See OCGA § 16-12-123. On appeal, Robinson claims the evidence was insufficient to support the verdict because the evidence presented demanded he be found not guilty by reason of insanity. We disagree and affirm.
[The] standard of appellate review of the sufficiency of the evidence with regard to a [trier of fact’s] finding of sanity in a criminal case is whether after reviewing the evidence in the light most favorable to the state, a rational trier of fact could have found that the defendant failed to prove by a preponderance of the evidence that he was insane at the time of the crime.
(Citation omitted.) Brown v. State, 250 Ga. 66, 71-72 (2) (c) (295 SE2d 727) (1982).
Robinson’s sole defense was that he should be found not guilty by reason of insanity because he acted under a delusional compulsion which overmastered his will to resist committing the crime. OCGA § 16-3-3. Robinson had the burden of proving his insanity by a preponderance of the evidence. Stevens v. State, 256 Ga. 440, 441 (350 SE2d 21) (1986). Furthermore, “[a] finding of insanity based upon OCGA § 16-3-3 requires proof that (1) the accused acted under a delusional compulsion; (2) the criminal act was connected with the delusion; and (3) the delusion related to a fact which, if true, would have justified the act.” (Citation omitted.) Appling v. State, 222 Ga. App. 327, 329 (3) (474 SE2d 237) (1996).
A forensic psychologist who had interviewed Robinson was the only witness to testify at trial. Robinson, Robinson’s attorney, and the district attorney agreed to admit the police report and witness statements into evidence with all facts asserted therein deemed proven and true. The parties stipulated that on August 17, 2002, Robinson was a passenger on a Greyhound bus traveling on Interstate 20 in Douglas County. According to the stipulation, Robinson grabbed the steering wheel of the bus without authority or justification and pulled on it in an attempt to cause the bus to veer onto the shoulder of the roadway. The parties further agreed that but for consideration of Robinson’s claim that he acted on a delusional compulsion, any rational trier of fact could find Robinson guilty of bus hijacking.
The police report and witness statements show that Robinson was seated behind the bus driver. Robinson told the driver he wanted
Shortly after Robinson left the bus, a police officer saw Robinson walking on the interstate. The officer, who had been dispatched to a reported Greyhound bus accident, stopped to ask Robinson if he had been involved in the incident. Robinson told the officer that people on the bus were trying to kill him, and, after additional questioning, Robinson asserted that the bus driver was “in on it as well.” The officer then detained Robinson.
At trial, the forensic psychologist testified that Robinson demonstrated the characteristics of an individual suffering from schizophrenia. It was the psychologist’s opinion that Robinson was capable of distinguishing right from wrong when the bus hijacking incident occurred, but that Robinson’s “behavior was being directed in the service of his paranoid delusions.” The psychologist further testified that “[a]t that time in Mr. Robinson’s world, people were trying to kill him and he was just taking appropriate action.” In the psychologist’s opinion, Robinson was acting under a delusional compulsion caused by a mental illness which overmastered his will to resist committing the crime.
Although the psychologist testified that in his opinion Robinson had acted out of a delusional compulsion, the psychologist’s testimony on cross-examination showed that Robinson did not tell the psychologist he tried to steer the bus in response to his delusion. To the contrary, the psychologist admitted Robinson’s “story at the time I interviewed him was that the bus driver was having some sort of difficulty.” The psychologist further admitted that Robinson told him that he feared the individuals on the bus were going to “jump” him. The psychologist testified that “jumping” does not equal “killing,” and that he got the word “kill” from notes he received from defense counsel.
Although the evidence shows Robinson suffered from a mental illness, this is insufficient to establish legal insanity under Georgia law. Rogers v. State, 195 Ga. App. 446, 447-448 (2) (394 SE2d 116) (1990). The second and third prongs of the test for establishing legal insanity under OCGA § 16-3-3 require that the criminal act be connected to the defendant’s delusion and that the delusion relate to a fact which, if true, would justify the act. See Stevens, supra, 256 Ga. at 442. Here, however, Robinson told the psychologist that he ended
Judgment affirmed.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.