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Behavioral Sciences and the Law
Behav. Sci. Law 28: 411–425 (2010)
Published online 14 December 2009 in Wiley InterScience
(www.interscience.wiley.com) DOI: 10.1002/bsl.913
Expert Testimony and the Effects of a
Biological Approach, Psychopathy,
and Juror Attitudes in Cases of Insanity
Jariel A. Rendell, B.A., Matthew T. Huss, Ph.D.* and
Maren L. Jensen, B.S.
Amid growing psychological controversy and legal interest surrounding the uses of
PCL-R and biological evidence in the legal system, this mock jury study assessed the
effects of PCL-R and biological evidence on outcomes in an insanity defense case. A
sample of 428 undergraduates read a trial transcript of an insanity defense murder case.
Three variables of interest were manipulated: rebuttal illness (no mental illness,
personality disorder, or psychopathy), evidentiary basis (biological or psychological),
and evidentiary strength (moderately strong or moderately weak). Consistent with the
hypotheses, biological evidence was more persuasive than psychological evidence, and
the rebuttal was slightly more successful when the prosecution labeled the defendant as
a ‘‘psychopath’’ than when they described him simply as ‘‘not mentally ill.’’ Copyright
# 2009 John Wiley & Sons, Ltd.
Though rarely used and even more rarely successful, the insanity defense remains
intensely controversial. The public tends to view the insanity defense with suspicion,
imagining that sane perpetrators of heinous crimes routinely feign mental illness to
escape criminal responsibility. Certainly influenced by John Hinckley’s acquittal
(United States v. Hinckley, 1981), the public’s negative perception of the insanity
defense led to dramatic reforms, which constricted or even eliminated the ‘‘not guilty by
reason of insanity’’ (NGRI) plea in many jurisdictions (Comprehensive Criminal
Reform Act, 1984). In legal, psychiatric, and psychological circles, these reforms and
their results have provoked vigorous debate. A more recent controversial aspect of
insanity cases is the use of the Psychopathy Checklist—Revised (PCL-R; Hare, 1991)
to rebut an insanity defense. In a review of PCL-R use in the courts, DeMatteo and
Edens (2006) reported that a psychologist testifying for the prosecution in an NGRI
trial concluded the defendant was malingering mental illness based in large part on his
conclusion that the defendant was a psychopath. Controversy over expert witness
testimony in insanity defense cases is hardly new, yet little research exists on the
presentation of PCL-R testimony by mental health expert witnesses, much less in
insanity cases. Therefore, the present study examined the effects of this type of mental health
expert testimony on mock juror decisions while manipulating additional related variables.
DeMatteo and Edens (2006) most recently highlighted the use of the PCL-R in
insanity cases, but concern over the role of the ‘‘psychopath’’ or ‘‘sociopath’’
diagnoses—terms often used interchangeably by the legal system—in insanity defense
*Correspondence to: Matthew T. Huss, Ph.D., Creighton University, Department of Psychology, 2500
California Plaza, Omaha, NE 68178. E-mail: [email protected]
Copyright # 2009 John Wiley & Sons, Ltd.
412
J. A. Rendell et al.
contexts is hardly new. In the 1950s, when the American Law Institute (1985) began to
draft standards for the insanity defense in the Model Penal Code, mental health and legal
experts debated the proper approach to psychopathy in the context of criminal
responsibility. Although the drafters generally agreed that legal systems should not
allow psychopathy to serve as the basis for an insanity defense, they nonetheless debated
the issue. In a letter to Herbert Wechsler, the chief reporter for the code, Manfred
Guttmacher, a psychiatrist, even argued that psychopaths ‘‘should be exculpated. . .
only where it can be shown or deduced that the individual has made real efforts to
control his criminal impulses and has found it impossible to do so’’ (as cited by
American Law Institute, 1985, p. 203). Nonetheless, the final draft of the code included
a rule designed specifically to prevent psychopathy from reducing criminal responsibility.
Even more interesting, approximately 50 years before DeMatteo and Edens (2006)
highlighted the issue, the drafters of the code (American Law Institute, 1985)
anticipated that prosecutors would use evidence of defendant psychopathy to rebut
insanity defenses. In his model jury instructions for use in insanity defense cases,
Wechsler expected prosecution expert testimony that ‘‘the accused was a psychopath or
sociopath’’ (as cited by American Law Institute, 1985, p. 213). Actual cases confirm
this prediction. Long before the advent of the PCL-R, prosecutors began to present
evidence of defendant psychopathy or sociopathy to rebut evidence of defendant mental
illness (see, e.g., Post v. State, 1978; State v. Steelman, 1978). Since then, prosecutors
across the United States have used psychopath/sociopath evidence to rebut NGRI
defenses in numerous cases (e.g., Beneby v. State, 2001; Carter v. State, 1993; People v.
Danks, 2004; People v. Scott, 1992; State v. Ferrell, 1995; State v. Jensen, 1987; Vardas v.
Estelle, 1983).
Though insanity defense cases overall are rare and insanity cases involving
psychopathy testimony even more so, psychopathy evidence appears in an increasing
number of mental-health-related legal settings. For example, prosecutors used such
testimony during the guilt/innocence phase of trials to rebut diminished capacity
defenses (e.g., Harris v. State, 2004; Penry v. Johnson, 2000). Prosecutors also have
presented testimony of defendant psychopathy in competency hearings to argue that a
defendant was competent to stand trial (e.g., State of Tennessee v. Reid, 2003) and in
sentencing hearings to rebut mitigating evidence of defendant mental illness or
retardation (e.g., Jones v. State, 2003; Penry v. Johnson, 2000).
Despite this apparently growing trend, research assessing the effects of such
testimony in insanity defense cases is extremely limited. The lack of research in this area
is troubling given that many of the cases involved were death penalty cases (e.g., People
v. Danks, 2004). Perhaps equally troubling is the reliance in recent cases on the PCL-R,
which is itself the subject of vigorous debate (e.g., Cooke & Michie, 2001; Hare &
Neumann, 2005; Lilienfeld, 1994). Some researchers (e.g., Cooke, Michie, & Skeem,
2007) argue in favor of a three-factor model for the PCL-R that excludes items related
to criminality (e.g., criminal versatility). Others (e.g., Hare, 2003; Hare & Neumann,
2005) argue for the inclusion of such items in four-factor model. Although including
criminal-behavior-related items increases the PCL-R’s ability to predict future violent
behavior (Skeem, Mulvey, & Grisso, 2003), it does not necessarily follow that criminal
behavior is part of the core construct of psychopathy. Most importantly, the use of
criminal behavior—even if accompanied by other criteria—to diagnose as psychopathic a defendant on trial for engaging in criminal behavior, especially in the context of
an NGRI case, gives cause for concern.
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
Expert testimony
413
In the absence of research on psychopathy-related testimony in insanity defense
cases, defense attorneys in at least one case (People v. Peets, 2004) sought to present
testimony that a defendant was not psychopathic as part of an insanity defense. Defense
attorneys in another case elected not to pursue an insanity defense rather than opening
the door for prosecutors to present rebuttal evidence of defendant sociopathy (Irick v.
State, 1998). The limited research on the prejudicial nature of the ‘‘psychopath’’ label in
the legal system suggests they may have been right to do so. Previous research examined
the impact of psychopathy in two situations in which it is commonly used: capitalsentencing hearings (Edens, Colwell, Desforges, & Fernandez, 2005; Edens, Desforges,
Fernandez, & Palac, 2004; Edens, Guy, & Fernandez, 2003) and sexually violent
predator (SVP) commitment hearings (Guy & Edens, 2003, 2006). Mock jurors were
more likely to support the death penalty for psychopathic defendants (Edens et al.,
2005, 2004, 2003), and female mock jurors were more likely to support civil
commitment for psychopathic SVP defendants than were their male counterparts (Guy
& Edens, 2003, 2006). These results suggest that the label of psychopathy is generally
prejudicial in the legal system but do not directly address use of the PCL-R to rebut the
insanity defense.
Legal scholars have begun to debate the role of biological determinants in insanity
cases, due in large part to recent developments in neuroscience, and the legal system is
increasingly attempting to use neuroscience to explain behavior in criminal cases.
Reider (1998) argued for revising and broadening current insanity tests based on
emerging research on biological connections between the brain and criminal actions.
For example, the widely used M’Naghten test of insanity impairment relies on cognitive
facets of impairment (i.e., the ability to distinguish the nature and quality or the
wrongfulness of behavior) rather than directly biological facets of impairment (e.g., the
capacity for emotion, feeling, and control). Reider’s proposed revision of insanity
defense standards would allow biological connections between the brain and criminal
behavior to serve as bases for the insanity defense, even in individuals without mental
illness. Other legal scholars share Reider’s belief in the importance of biological evidence
even if they do not agree with her conclusions. Redding (2006), for example, described
recent empirical findings on criminal defendants with brain damage and argued that courts
should give greater weight to neuroscience evidence. Specifically, Redding argued that
frontal lobe damage severe enough to impair behavioral controls should serve as grounds
for NGRI pleas. Under current standards, biological evidence of neurological
abnormalities alone does not generally satisfy the legal requirements for an NGRI verdict.
Despite increasing debate about such testimony among legal scholars, there is little
research on the use of biological testimony. Several psychologists, however, researched
the effects of various forms of expert testimony presentation that may tangentially relate
to the biological versus psychological distinction in the minds of jurors. Bornstein
(2004) compared the effects of anecdotal and experimental non-psychological expert
testimony in a civil trial; he found that only anecdotal testimony influenced verdicts.
Krauss and Sales (2001) obtained similar results in a study comparing clinical
opinion testimony with actuarial testimony in the sentencing phase of a mock capital
murder trial. Jurors found an expert more convincing when he rendered his decisions
based on clinical experience rather than empirically validated tests. A Canadian
study by Gelinas and Alain (1993), in contrast, found that, although jurors viewed
anecdotal expert testimony more favorably, statistical expert testimony was more
convincing.
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
414
J. A. Rendell et al.
Although research on general biological evidence is limited, a growing body of
scholarship has considered the use of neuroimaging testimony in legal contexts. Of
particular interest for the present study, Gurley and Marcus (2008) conducted
psychological research on the effect on mock jury verdicts of neuroimaging testimony in
an insanity defense case. Their results indicated that introducing MRI brain scans and
offering evidence that a defendant suffered brain damage both increased the likelihood
that mock jurors would find the defendant NGRI. Unusually, however, their study used
both schizophrenia and psychopathy as bases for an insanity defense, despite the fact
that insanity defense standards (e.g., American Law Institute, 1985) specifically bar the
use of psychopathy for this purpose. Furthermore, Gurley and Marcus (2008) merely
added or removed neuroimaging and brain injury evidence rather than comparing them
with other types of evidence.
Beyond psychological circles, neuroimaging testimony is an issue of keen interest to
legal scholars. Feigenson (2006), for example, described the emerging use of functional
magnetic resonance imaging (fMRI) evidence in court and argued in favor of admitting
such evidence with certain safeguards. Moriarty (2008) reviewed some of the key legal
questions surrounding neuroimaging, including the reliability and admissibility of such
testimony, and concluded that scholarly debate and legal challenges to neuroimaging
evidence are likely to continue as courts struggle to respond to such evidence. Perlin
(2009) posed important questions on the broader issue of the potential value of
neuroimaging evidence, musing that such evidence is unlikely to become the decisive,
objective source of clarity some hope it could be in insanity defense cases.
In sum, expert testimony based on biological evidence continues to be a source of
vigorous study and debate in psychological and legal circles. The highly limited
psychological research in this area indicates that jurors are sensitive to distinctions in
expert testimony, which potentially could include the biological versus psychological
distinction. Neuroimaging evidence may increase jurors’ tendencies to favor NGRI
verdicts, but the relative value of such evidence is unclear. Similarly, it is unclear
whether statistically based testimony, such as evidence of abnormal scores on
empirically validated psychological tests, is less convincing than testimony based on
other evidence, including clinical opinion, anecdotal, and biological evidence. These
questions are especially important given the legal system’s ongoing struggle to find the
appropriate legal responses to various forms of biological evidence.
Although the substance and presentation of cases are important, the role of jurors’
own attitudes and personalities in verdict decisions should not be ignored. A compelling
body of evidence indicates that legal authoritarianism affects both juror and jury
verdicts (Narby, Cutler, & Moran, 1993; Shaffer & Wheatman, 2000). Its effect has
been especially high in cases involving mental illness (Narby et al., 1993). In insanity
defense cases, the role of juror attitudes may be especially important. Skeem and
Golding (2001) examined jurors’ and undergraduate students’ prototypes of insanity
and their relationship to insanity defense attitudes. Results indicated that jurors do not
limit their conceptions of insanity to legal definitions. Furthermore, jurors’ attitudes
toward the insanity defense not only influence their case-specific attitudes and verdict
decisions, but also bias their interpretation of information. Therefore, it is imperative to
account for these attitudes in mock jury insanity defense research.
The present study examined the effect of several factors that appear to be increasingly
relevant to insanity cases as certain legal and psychological trends develop. In this
particular study, the defense’s expert testified that the defendant had schizophrenia.
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
Expert testimony
415
The defense expert supported his diagnosis with either biological or psychological
evidence. In contrast, an expert testified for the prosecution that the defendant either
(1) was a ‘‘psychopath,’’ (2) had a ‘‘personality disorder,’’ or (3) was ‘‘not mentally ill.’’
The condition involving a personality disorder identical to psychopathy in all but name
was used to separate the effects of the term ‘‘psychopath’’ from the personality traits it
represents. In order to account for jurors’ attitudes toward the insanity defense and legal
authoritarianism, the present study included scales measuring these attitudes and
personality traits. Attitudes toward the insanity defense were measured using the
Insanity Defense Attitudes—Revised (IDA-R) scale (Skeem, Louden, & Evans, 2004).
Legal authoritarianism was assessed using the Revised Legal Attitudes Questionnaire
(RLAQ; Kravitz, Cutler, & Brock, 1993). In addition, the defense’s case was either
moderately strong or moderately weak. Research by Pickel (1998) indicated that jurors
are more likely to support insanity acquittals when motive and crime behavior are
unusual. Thus, the moderately strong defense case included evidence of unusual
behavior and motive, while the moderately weak case included evidence of a rational
motive without unusual behavior.
The first hypothesis of the current study was that labeling the defendant as a
psychopath would be more successful than testimony that the defendant was not
mentally ill or had a personality disorder in rebutting the defense’s insanity case. The
second hypothesis was that defense expert testimony based on biological evidence
would be more successful in supporting the defense’s NGRI plea than testimony based
on psychological evidence. The third hypothesis was that jurors with high legal
authoritarianism and negative attitudes toward the insanity defense would be more
conviction prone than jurors with lower legal authoritarianism and more positive
attitudes toward the insanity defense. The final hypothesis was that jurors would be
more supportive of the defense’s case in the moderately strong defense condition than in
the moderately weak defense condition.
METHOD
Participants
A sample of 428 students was recruited primarily from introductory psychology classes
at a private Midwestern university. In exchange for participation, students received
credit in their psychology classes. By self-report, participants were predominantly
young (M ¼ 18.99, SD ¼ 1.18), White (81.6%), female (62.4%), and registered to vote
(71.8%). The sample was 6.6% Asian, 4.2% Hispanic or Latino, 3.1% Black or African
American, 2.1% Native Hawaiian and Other Pacific Islander, and .7% American Indian
and Alaska Native. A small number (1.7%) of participants did not report their race. The
majority of participants were freshmen (61.9%), but sophomores (26.1%), juniors (8.0%),
and seniors (3.8%) also participated. A small number of participants (.2%) did not list their
class. Two of the 428 students did not complete the demographic questionnaire.
Materials
In order to assess participants’ legal authoritarian and insanity defense attitudes, two
attitude measures were used. Legal authoritarianism was assessed using the RLAQ
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
416
J. A. Rendell et al.
(Kravitz et al., 1993). The IDA-R (Skeem et al., 2004) was used to assess participants’
insanity defense attitudes. In addition to the attitude measures, study material included
trial transcripts, verdict questionnaires, and demographic questionnaires.
Revised Legal Attitudes Questionnaire (RLAQ)
The 30-item self-report RLAQ (Kravitz et al., 1993) provides a single score for legal
authoritarianism by assessing three subscales: Authoritarianism, Equalitarianism, and
Anti-authoritarianism. Participants respond to statements (e.g., ‘‘There is no need in a
criminal case for the accused to prove his innocence beyond a reasonable doubt.’’)
along a seven-point Likert scale ranging from 1 (strongly disagree) to 7 (strongly agree).
The RLAQ is a shortened and revised version of the original Legal Attitudes
Questionnaire (LAQ; Boehm, 1968) demonstrating improved internal reliability and
construct validity. Narby et al. (1993) conducted a meta-analysis evaluating the
relationship between authoritarian attitudes and verdicts. Their analysis found a
reliable correlation between juror legal authoritarianism and both juror and jury
verdicts. Correlations between legal authoritarianism and conviction rates tended to be
higher in cases involving mental illness than in other cases. Overall, their results
indicated that using the RLAQ to measure potential jurors’ legal authoritarian
personality traits can provide important clues regarding prospective jurors’ propensities
to convict or acquit, especially in cases involving mental illness.
Insanity Defense Attitudes—Revised Scale (IDA-R)
The IDA-R is a revised version of the Insanity Defense Attitudes scale and consists of 19
core questions and three general opinion questions to assess juror bias in cases involving
the insanity defense (Skeem et al., 2004). Participants rate their responses using a
seven-point Likert scale ranging from 1 (strongly disagree) to 7 (strongly agree). Skeem
et al. (2004) found that the IDA-R measured two factors: Strict Liability, and Perceived
Injustice and Danger. Strict Liability questions measured beliefs about the mitigating
effects of mental illness on criminal responsibility. An individual who believed, for
example, that mentally ill people who commit crimes should be held fully responsible
regardless of impairment likely had a high Strict Liability score. Perceived Injustice and
Danger questions measured beliefs regarding the potential injustice and danger
associated with the successful use of the insanity defense. For example, an individual
who believed that mentally ill defendants in successful insanity defense cases were likely
to harm members of the public likely had a high Perceived Injustice and Danger score.
The IDA-R measures both factors with good internal consistency, convergent and
divergent validity, and predictive utility (Skeem et al., 2004).
Trial Transcripts
Case material consisted of a 16-page trial transcript summarizing a hypothetical trial
based on real cases. The basic case facts used in the transcript were drawn from United
States v. Weed (2004), in which the defendant was found not guilty by reason of insanity
for the second-degree murder of a federal employee. Testimony indicating that Weed
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
Expert testimony
417
was not psychopathic was presented as part of his commitment proceedings after the
criminal trial, but no testimony regarding psychopathy was presented in the criminal
trial. Other cases, therefore, were used to develop the manipulations of the three
independent variables examined in the present study: (1) the mental health evidence
used by the prosecution to rebut the insanity defense, (2) the evidence used by
the defense mental health expert to diagnose the defendant’s alleged schizophrenia, and
(3) the strength of the defense’s insanity case. The evidentiary manipulations resulted in
12 different trial transcripts.
The trial transcript contained three conditions for the first independent variable.
Specifically, the prosecution’s rebuttal mental health expert testified that the defendant
was not schizophrenic, but rather that the defendant was (a) psychopathic, (b) personality disordered, or (c) not mentally ill. The diagnosis of a personality disorder, which
was identical to psychopathy in all but name, was used in order to assess the prejudicial
nature of the psychopathic label. The second independent variable, the basis for the
defense mental health expert’s diagnosis of schizophrenia, assessed the influence of
biologically based mental health evidence on participants’ verdicts. In the first
condition, the defense expert based his schizophrenia diagnosis on biological evidence
including neurochemical imbalances and hypofrontality in the defendant’s brain.
Testimony in the psychological condition, in contrast, was based on the defendant’s
results on traditional psychological tests such as the Minnesota Multiphasic Personality
Inventory-2 (MMPI-2; Butcher et al., 2001). The third independent variable, defense
case strength, had two conditions. In the first condition, the defense’s insanity case was
based on moderately strong evidence (i.e., unusual crime elements and an irrational
motive). In contrast, the second condition involved a moderately weak defense case
(i.e., typical crime elements and a reasonable motive).
Verdict and Demographic Questionnaires
In order to assess mock jurors’ verdicts, participants received a short verdict
questionnaire consisting of multiple-choice and short answer questions. After rendering
a verdict and reporting their verdict confidence, participants completed several other
trial outcome-related questions including sentence length. Upon completion of the
verdict-related questions, participants answered the manipulation check questions,
which assessed their understanding of the expert witness testimony (i.e., ‘‘According to
the Government’s mental health expert, what was the defendant’s mental illness?’’ and
‘‘According to the Defense’s mental health expert, what was the defendant’s mental
illness?’’). Lastly, participants completed a brief demographic questionnaire.
Procedure
Participants were randomly assigned to one of 12 conditions sharing the same
procedure. After arriving at the study location, which was a traditional classroom,
students were asked to read and sign consent forms if they wished to participate. After
the forms were collected, participants were given coded packets containing the RLAQ,
the IDA-R, the trial transcript, the verdict questionnaire, and the demographic
questionnaire. In order to account for the possibility that completing the attitude
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
418
J. A. Rendell et al.
measures before reading the transcript could influence participants’ perceptions of the
transcript, the attitude measures were counterbalanced such that approximately half of
the participants received the IDA-R before the trial transcript and the rest received it
after the trial transcript. After receiving the packets, participants were instructed to read
and complete the questionnaires carefully. Upon completion of the questionnaires,
participants were directed to read the trial transcript carefully and silently. Once the
participants read the trial transcript, which included judicial instructions to jurors, the
researchers collected the trial transcripts in order to prevent participants from returning
to the transcript while completing the manipulation check questions. Upon completion
of the remaining questionnaires, participants were debriefed and advised not to discuss
the results of the study in the presence of anyone who had not participated.
RESULTS
Before testing any hypotheses, participants’ responses to the manipulation check
questions were examined to assess the salience of the independent variables.
Participants who failed either of the manipulation check questions (n ¼ 50; 11.5%)
were excluded from the final analyses. The remaining participants (n ¼ 383) remained
largely young (M ¼ 19.01, SD ¼ 1.19), white (81.6%), female (59.8%), and registered
to vote (71.8%). Several analyses were conducted to compare the demographics of the
final and excluded samples; there was one significant demographic difference between
the samples. A higher proportion of women failed the manipulation check (n ¼ 39;
14.6%) relative to men (n ¼ 7; 4.5%). In each condition in the final sample, the number
of participants was largely equal, ranging from n ¼ 30 to n ¼ 33. After identifying the
final sample, the hypotheses were tested by examining three types of outcome variable
in addition to convicting jurors’ sentencing recommendations: primary verdict,
defendant blame, and mental illness responsibility. Analyses were conducted using
either an analysis of covariance (ANCOVA) or a multivariate analysis of covariance
(MANCOVA) where appropriate.
Primary Verdict Measures
To test the effect of the independent variables on juror verdicts, analyses were
conducted on the two primary verdict measures: dichotomous verdict choice and
verdict confidence. Because verdict choice was a categorical variable, chi square
statistics and an independent sample t-test were used to test the hypotheses with regard
to verdict. As shown in Table 1, participants were more likely to find the defendant
NGRI when defense expert testimony was based on biological rather than psychological
evidence, x2(1, 382) ¼ 5.808, p ¼ .018, h2 ¼ .123, and when the defense’s case was
moderately strong rather than moderately weak, x2(1, 382) ¼ 14.985, p < .001,
h2 ¼ .198. There was no difference between conviction rates across the three rebuttal
illness conditions, x2(1, 382) ¼ 2.486, p ¼ .288, h2 ¼ .078. Independent sample t-tests
on RLAQ and IDA-R score differences revealed that convicting mock jurors tended to
have higher RLAQ scores (M ¼ 98.531, SD ¼ 11.626) and IDA-R scores (M ¼ 82.641,
SD ¼ 18.644) than their non-convicting counterparts (RLAQ, M ¼ 92.894,
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
Expert testimony
419
Table 1. Verdict decisions by evidence type, case strength, and rebuttal testimony
Defense evidence type
Biological
Psychological
Defense case strength
Moderately strong
Moderately weak
Prosecution rebuttal testimony
No mental illness
Personality disorder
Psychopathy
Guilty (%)
NGRI (%)
49.2
61.5
50.8
38.5
45.6
65.3
54.4
34.7
50.0
56.7
59.5
50.0
43.3
40.5
SD ¼ 12.729; IDA-R, M ¼ 65.693, SD ¼ 16.461; RLAQ, t(379) ¼ 4.507, p < .001;
IDA-R, t(374) ¼ 9.237, p < .001.
After rendering a verdict, the questionnaire asked participants to indicate their
confidence in their verdict on a Likert scale ranging from 1 to 7. Combining the
confidence ratings with verdict yielded verdict confidence, which ranged from 1
(extremely confident NGRI) to 14 (extremely confident guilty). The effects of the
independent variables on verdict confidence were tested using a 3 (rebuttal illness) 2
(basis) 2 (strength) ANCOVA with RLAQ and IDA-R scores as covariates. Both the
RLAQ, F(1, 373) ¼ 8.511, p ¼ .004, h2 ¼ .023, and the IDA-R, F(1, 373) ¼ 74.719,
p < .001, h2 ¼ .172, were significant covariates of verdict confidence. There were also
main effects of rebuttal illness, F(2, 372) ¼ 4.385, p ¼ .013, h2 ¼ .024, basis, F(1,
373) ¼ 7.251, p ¼ .007, h2 ¼ .020, and strength, F(1, 373) ¼ 20.786, p < .001,
h2 ¼ .055, and an unexpected three-way interaction between illness, basis, and
strength, F(2, 372) ¼ 74.7, p ¼ .048, h2 ¼ .017. Table 2 contains descriptive statistics.
Defendant Blame Variables
There were two related indicators of the level of blame that jurors ascribed to the
defendant for his behavior: percentage of guilt assigned to the defendant and percentage
of responsibility assigned to the defendant for his actions. Both variables ranged from 0
to 100% in increments of 10. The effects of the three independent variables were tested
using a 3 (rebuttal illness) 2 (basis) 2 (strength) MANCOVA with RLAQ and IDAR scores as covariates on defendant blame. Results indicated that both RLAQ, F(2,
372) ¼ 4.052, p ¼ .018, h2 ¼ .022, and IDA-R, F(2, 372) ¼ 58.793, p < .001, h2 ¼ .247,
scores were significant covariates of the defendant blame measures. There was no
significant difference between mental illness conditions, F(4, 370) ¼ 1.147, p ¼ .333,
h2 ¼ .006, or basis conditions, F(2, 372) ¼ 2.027, p ¼ .133, h2 ¼ .011. There was,
however, a main effect of strength, F(2, 372) ¼ 11.446, p < .001, h2 ¼ .060. Participants
tended to assign a higher guilt level to the defendant in the moderately weak condition
(M ¼ 67.081, SD ¼ 27.783) than in the moderately strong condition (M ¼ 58.484,
SD ¼ 30.345), F(1, 373) ¼ 9.360, p ¼ .002, h2 ¼ .025. Participants also regarded the
defendant as more responsible for his behavior in the moderately weak condition
(M ¼ 68.432, SD ¼ 28.953) than in the moderately strong condition (M ¼ 55.426,
SD ¼ 31.100), F(1, 373) ¼ 22.946, p < .001, h2 ¼ .060.
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
420
J. A. Rendell et al.
Table 2. Verdict confidence and standard deviation by evidence type, case strength, and rebuttal testimony
Case manipulation
Biological evidence
Moderately strong case
No mental illness
Personality disorder
Psychopathy
Moderately weak case
No mental illness
Personality disorder
Psychopathy
Psychological evidence
Moderately strong case
No mental illness
Personality disorder
Psychopathy
Moderately weak case
No mental illness
Personality disorder
Psychopathy
Moderately strong case
Moderately weak case
No mental illness
Personality disorder
Psychopathy
Verdict confidence
SD
7.56
4.97
6.94
5.97
6.97
5.05
4.63
5.30
6.80
9.69
9.24
8.77
5.09
4.63
4.27
4.71
6.67
8.26
8.33
5.05
4.97
4.60
9.33
9.75
10.28
7.17
9.20
7.45
8.41
8.71
4.41
4.46
4.13
4.95
4.58
4.97
4.87
4.71
Mental Illness Responsibility Variables
There were three variables measuring the level of blame for the crime participants
ascribed to the defendant’s alleged mental illness: the percentage of responsibility,
ranging from 0 to 100% in increments of ten, for the defendant’s actions that
participants assigned to the mental illness; the severity of the defendant’s alleged
schizophrenia, ranging from 1(not at all severe) to 7 (extremely severe); and the
likelihood that the defendant would benefit from mental health treatment, ranging from
0 to 100% in increments of ten. The analysis of the effects of the case manipulations on
the three mental illness measures began with a 3 (rebuttal illness) 2 (basis) 2
(strength) MANCOVA with RLAQ and IDA-R scores as covariates. Because the
RLAQ was not a significant covariate, F(3, 371) ¼ 2.621, p ¼ .051, h2 ¼ .022, the final
analysis removed the RLAQ from the MANCOVA. In the final MANCOVA, the IDAR was a significant covariate of the mental illness blame measures, F(3, 371) ¼ 27.450,
p < .001, h2 ¼ .187. There was no main effect of rebuttal illness, F(6, 368) ¼ .956,
p ¼ .454, h2 ¼ .008, but there were main effects of basis, F(3, 371) ¼ 3.370, p ¼ .019,
h2 ¼ .027, and strength, F(3, 371) ¼ 9.902, p < .001, h2 ¼ .076.
Participants tended to assign a higher level of responsibility to the schizophrenia
when the defense expert testimony was based on biological evidence (M ¼ 52.473,
SD ¼ 33.257) than when it was based on psychological testimony (M ¼ 44.421,
SD ¼ 31.209), F(1, 373) ¼ 8.149, p ¼ .005, h2 ¼ .022, and when the defense’s case was
moderately strong (M ¼ 55.401, SD ¼ 32.116) than when it was moderately weak
(M ¼ 41.243, SD ¼ 31.261), F(1, 373) ¼ 23.114, p < .001, h2 ¼ .060. Participants
believed that the defendant’s alleged schizophrenia was more severe in the biological
condition (M ¼ 3.995, SD ¼ 1.979) than in the psychological condition (M ¼ 3.484,
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
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421
SD ¼ 1.888), F(1, 373) ¼ 8.703, p ¼ .003, h2 ¼ .024, and in the moderately strong
condition (M ¼ 4.198, SD ¼ 1.937) than in the moderately weak condition (M ¼ 3.265,
SD ¼ 1.847), F(1, 373) ¼ 27.402, p < .001, h2 ¼ .071. Participants also believed that
the defendant was more likely to benefit from mental health treatment in the biological
condition (M ¼ 53.587, SD ¼ 28.403) than in the psychological condition (M ¼
47.895, SD ¼ 26.801), F(1, 373) ¼ 4.199, p ¼ .041, h2 ¼ .011. There was a moderately
significant difference between treatment benefit ratings in the moderately strong
condition (M ¼ 53.492, SD ¼ 26.787) and the moderately weak condition
(M ¼ 47.838, SD ¼ 28.412), F(1, 373) ¼ 3.872, p ¼ .050, h2 ¼ .011.
Sentences
In addition, participants who found the defendant guilty recommended a sentence of 0
(no prison time) to 50 (life) years in federal prison. A 3 (rebuttal illness) 2 (basis) 2
(strength) analysis of covariance (ANCOVA) with RLAQ and IDA-R scores as
covariates tested the effects of the case manipulations and attitudes on sentencing
recommendations. Because the RLAQ was not a significant covariate, F(1,
201) ¼ 1.667, p ¼ .198, h2 ¼ .009, the final analysis used an ANCOVA without the
RLAQ as a covariate. The analyses revealed the IDA-R as a significant covariate, F(1,
201) ¼ 4.267, p ¼ .040, h2 ¼ .022, but revealed no significant main effects or
interactions.
DISCUSSION
Results from the present study offered support for all the hypotheses. The prediction
that labeling the defendant as a psychopath would rebut the defense’s case more
successfully than testimony that the defendant was not mentally ill or had a personality
disorder received mixed support. According to verdict confidence ratings, mock jurors
were more confidently conviction prone when prosecution testimony labeled the
defendant a psychopath than when the prosecution described the defendant as not
mentally ill. The second hypothesis, which was that defense expert testimony based on
biological evidence would be more successful in supporting the defense’s NGRI plea
than testimony based on psychological evidence, was supported. According to both of
the primary verdict measures, verdict and verdict confidence, the defense was more
successful when its expert presented biological evidence. Biological evidence also led
mock jurors to view the defendant’s schizophrenia as more severe and more responsible
for his criminal behavior. The hypothesis that jurors with high legal authoritarianism
and negative attitudes toward the insanity defense would be more conviction prone than
jurors with lower legal authoritarianism and more positive attitudes toward the insanity
defense was supported by all but two measures. Specifically, mock jurors’ scores on the
RLAQ were not associated with their sentencing recommendations or mental illness
blame ratings. As expected, jurors were more supportive of the defense’s case in the
moderately strong defense condition than in the moderately weak defense condition,
but case strength did not affect sentencing recommendations.
Findings in the present study regarding the prejudicial effect of the psychopathy label
were generally consistent with previous research. When the prosecution offered
Copyright # 2009 John Wiley & Sons, Ltd.
Behav. Sci. Law 28: 411–425 (2010)
DOI: 10.1002/bsl
422
J. A. Rendell et al.
evidence of defendant psychopathy, mock jurors were more confidently conviction
prone. Psychopathy testimony did not affect outright verdicts, defendant blame
indicators, or mental illness responsibility indicators. Thus, the concern of DeMatteo
and Edens (2006) about the use of the PCL-R to rebut an insanity defense seems
warranted to some extent. It must be noted, however, that the effect of rebuttal illness
on verdict confidence ratings (h2 ¼ .024), though significant, was slight compared to the
influence of jurors’ own attitudes toward the insanity defense as measured by the IDA-R
(h2 ¼ .172). Other research also indicates that attitudes toward the insanity defense
have a powerful influence on juror verdicts. The study by Louden and Skeem (2007) of
the relative influences on verdict decisions of jurors’ attitudes toward the insanity
defense and conceptions of the prototypical ‘‘insane’’ defendant indicated that insanity
defense attitudes affected jurors’ case evaluations to such an extent that jurors’
conceptions of the characteristics of ‘‘insane’’ defendants became almost meaningless
in comparison. Nevertheless, several factors in the present study, including rebuttal
illness, affected juror judgments and verdicts beyond the influence of insanity defense
attitudes.
The present study provides the first comparison of the influence on juror decision
making of biological and psychological evidence in a legal setting. Overall, mock jurors
tended to find biological evidence more persuasive. When the defense based its insanity
defense case on biological evidence, jurors were more likely to find the defendant NGRI
in terms of verdict and verdict confidence. Biological evidence led jurors to view the
defendant’s mental illness as more severe, more responsible for his criminal behavior,
and more treatable. Interestingly, there were no differences in defendant guilt and
responsibility ratings between biological and psychological conditions. These results
have several interesting implications. Obviously, they suggest that insanity defenses
might be more successful if based on biological evidence, such as neurological tests,
rather than purely on psychological evidence, including standardized assessments such
as the MMPI-II.
Perhaps equally interesting, the pattern of results may provide an interesting glimpse
into juror decision-making processes in insanity defense cases. Although perceptions of
the defendant’s guilt and responsibility remained consistent, biological evidence led to
lower conviction rates. Essentially, although defendant responsibility ratings remained
fixed, shifting mental illness responsibility ratings coincided with shifting verdict
decisions. One interpretation is that evidence in an insanity defense case leading jurors
to view the defendant as more severely mentally ill need not affect jurors’ perceptions of
the defendant’s responsibility to in order to reduce their tendency to convict. This
interpretation would suggest that jurors use some form of mental calculation to weigh
mental illness responsibility against defendant responsibility. For example, some jurors
could require that mental illness responsibility meet a minimum threshold in order to
result in an NGRI verdict, or jurors might render NGRI verdicts only when they ascribe
more responsibility to the defendant’s mental illness than to the defendant.
Consistent with previous research (Pickel, 1998), the present study’s comparison of
defense case strength clearly indicated that jurors were more likely to convict when the
defense’s case was moderately weak. The key differences between the conditions hinged
on the presence of unusual behavior and an irrational motive. Thus, the absence of
unusual behavior and the suggestion of a rational motive led to the higher conviction
rate in the weak defense condition relative to the strong defense condition. The sharp
difference occurred even though there were few differences in testimony between the
Copyright # 2009 John Wiley & Sons, Ltd.
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DOI: 10.1002/bsl
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423
conditions, which implied that mock jurors were sensitive to certain evidence. It is less
clear to what extent they weighed the evidence in a manner consistent with the legal
expectations. As Pickel (1998) noted, an irrational motive provides evidence regarding
a defendant’s mental state surrounding the criminal act. Evidence of an irrational
motive alone, however, would not meet the federal NGRI standard. For example, an
individual committing a criminal act, knowing it to be immoral, could not avoid
culpability simply because the motive for the behavior was irrational.
The same principle applies to unusual criminal behavior. Although evidence of
unusual behavior can clarify a defendant’s mental state, it should not outweigh more
probative evidence such as psychological testimony regarding the defendant’s mental
health. After all, a mentally sound defendant should not be able to avoid legal
responsibility by behaving unusually. Because the goal of the present study was to
compare the effects of certain types of expert testimony on NGRI defenses of varying
strength, the differential effect of unusual behavior and irrational motive on juror
verdicts is unclear. In previous research (Pickel, 1998), which separated the influence of
unusual behavior and irrational motive, each factor alone exerted some influence over
verdicts.
In psychological mock jury research, replicating real-world trial conditions is
generally difficult. No exception, this study shares several limitations with most other
research of this type. First, the case material consisted of a relatively simple and short
trial transcript. Real-world trial transcripts can often cover hundreds of pages, many
filled with legal terminology, and trials involving testimony from numerous witnesses
can last days or even weeks. It is possible that more extensive and detailed case stimuli
would result in different findings, and this possibility is a worthy subject for future
research. The 16-page transcript used in this study, however, was longer and more
detailed than case stimuli used in most other mock jury studies examining similar
psycholegal issues (e.g., Guy & Edens, 2003). Unlike most other research in this area,
moreover, this study’s case stimuli included opening and closing arguments for both
sides as well as testimony by multiple witnesses, including relatively detailed expert
witness testimony. Another improvement over previous research is this study’s
inclusion of expert testimony cross-examination. It seems unlikely, therefore, that more
extensive stimuli would lead to markedly different results.
The second limitation stems from the composition of the sample. By several
demographic measures, such as age, college students differ from actual jurors. Thus, it
is conceivable that actual jurors might view certain aspects of the case differently.
However, findings from previous research on differences between student, community,
and actual jury samples are instructive. In a review of 26 studies comparing results
across samples, Bornstein (1999) reported that differences between samples were rare
and inconsistent. Furthermore, a study (Roberts & Golding, 1991) comparing student
and community participants’ verdicts in an insanity defense case found no differences
between samples.
Future research examining these limitations would be quite interesting, especially in
the context of psychopathy. Of the growing number of studies examining the influence
of psychopathy testimony on mock jurors, none has compared effects across multiple
sample types. In future research, it would also be interesting to examine participants’
pre-existing beliefs about psychopathy. Though the present study controlled for the
potentially prejudicial effect of the ‘‘psychopath’’ label, it did not control for
participants’ pre-existing knowledge of psychopathy. Such research may be especially
Copyright # 2009 John Wiley & Sons, Ltd.
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DOI: 10.1002/bsl
424
J. A. Rendell et al.
important given growing concern over potentially inappropriate use of the PCL-R in
legal settings (DeMatteo & Edens, 2006).
Given that the present study provided the first mock jury comparison of biological
with psychological evidence in an insanity defense case, future research should extend
these findings beyond the insanity defense. Other legal settings worthy of research could
include mental health expert testimony bolstered by biological evidence; for example, a
defendant could use biological evidence to support evidence of mental impairment in
the sentencing phase of a capital murder case. Such research may be especially
important in light of the legal system’s interest in neurological evidence, which is likely
to increase in the coming years with the emergence of improved technologies for
studying the brain and accompanying scientific breakthroughs in understanding the
biological underpinnings of mental illness.
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DOI: 10.1002/bsl
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