California Court of Appeals Denies Appeal of Man Diagnosed With Schizophrenia and Possible Frontal Lobe Damage
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
Keith Brown pled guilty to second-degree murder when he was 16 years old. Thirty-two years later, with MRI evidence suggesting brain damage to his frontal lobe, Brown filed a request for coram nobis relief to vacate his murder conviction. The trial court denied the request in 2019, and on July 30, 2020, the California Court of Appeal Second District affirmed that denial.
In 1987, after Brown entered his guilty plea, the California trial court sentenced him to 17 years in prison. 32 years later, in 2019, Brown filed a motion for coram nobis relief, asking the trial court to vacate his conviction due to new evidence related to Brown’s cognitive state at the time he entered his guilty plea. In 2015, four years prior to Brown filing his motion, a psychologist diagnosed Brown with schizophrenia and said that Brown had likely had the disorder since he was 10 years old. Additionally, the psychologist noted that Brown had potential brain damage in his frontal lobe which was noted during a 2013 MRI scan. In his motion, Brown claimed that he was “unaware of his ‘mental defect’ when he entered his guilty plea to the murder charge and this ‘insanity’ at the time prevented him from mounting an insanity defense.” He also claimed that he was misled into falsely thinking that by entering the guilty plea, he would only serve 10 years in a juvenile facility because of his youthful age at the time of his offense.
Despite the arguments he raised, the trial court denied his request in 2019. Brown appealed the ruling to the California Court of Appeal Second District, which on July 30, 2020, upheld the trial court’s 2019 decision. The Court of Appeals stated that there was no “prima facie case of due diligence” to grant him coram nobis relief due to the fact that Brown submitted the request for coram nobis relief over four years after he had learned of his schizophrenia diagnosis and possible brain damage.
In the dissenting opinion, presiding Judge Laurence Rubin stated that he believed the trial court erred. He wrote: “The record does not establish that, at any time relevant to the current petition, Brown had the assistance of counsel. We, likely do not have a complete picture of the four years it took him to file his coram nobis petition . . . We might reasonably infer that Brown’s lack of counsel, his lack of a high school education, and his severe mental deficiencies contributed to his delay.”
Key Words: coram nobis, brain damage, frontal lobes, schizophrenia, California
Citation: People v. Brown
This post is 18th 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.