Defendant Claims that she Unknowingly Entered into a Guilty Plea due to her Cognitive Limitations, but Maine’s Supreme Judicial Court Denies Appeal
Recent Cases in Law and Neuroscience, Curated by the Center for Law, Brain & Behavior and the Shen Neurolaw Lab with support from the Dana Foundation
After a trial court denied defendant Kandee Weyland’s motion to withdraw her guilty plea despite expert witness testimony stating that “[Weyland] suffers from traumatic brain injury, post-traumatic stress disorder, depressive disorder, and anxiety disorder,” Weyland appealed her conviction to the Supreme Judicial Court of Maine on September 15, 2020.
In February 2017, Weyland, aged 46, was charged with the murder of her ex-husband after she stabbed him to death in Acton, Maine. On August 27, 2018, Weyland entered an unconditional guilty plea to the murder charge. On October 26, 2018, before her sentencing, Weyland filed a motion to the court to withdraw her guilty plea. She asserted that “she had not taken her prescribed medication on the day of the [hearing] and that she has limited cognitive capacity.” After the trial court denied her motion, Weyland appealed to the Maine Supreme Judicial Court.
In her appeal, Weyland argued that “she had not entered a knowing plea because she did not understand the mens rea element of the murder charge” due to her “cognitive limitations.” She also argued that she “suffers from an abnormal state of mind” and that “the court should have allowed her to pursue that theory at trial.”
On November 3, 2020, the court denied her appeal. They stated that Weyland “did not present evidence linking her abnormal condition of the mind to any inability to act with a culpable state of mind in committing the crime.” According to Maine’s criminal code, “when a defendant claims that he or she suffers from an abnormal condition of the mind, the defendant must proffer some evidence of the condition and of his or her inability to act with the requisite state of mind.” During the hearing of her motion to withdraw her guilty plea, while her expert witness spoke of her traumatic brain injury and mental disorders, he “did not testify that those diagnoses might have prevented Weyland from acting with a culpable state of mind at the time she killed the victim.”
Weyland’s conviction and sentence of 32 years imprisonment was upheld.
Key words: traumatic brain injury, PTSD, mens rea, cognitive deficit, guilty plea, Maine
Citation: State of Maine v. Kandee A. Weyland, 2020 WL 6437674
This post is the 22nd post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.