The Supreme Court has ruled that a trial judge should not set aside an accused person’s guilty plea to raise an issue about the person’s sanity unless quite exceptional circumstances arise.
The decision came on a consultative case stated from the Western Circuit. Circuit Court judge Haugh J. asked whether he could or should reject a guilty plea and enter a not guilty plea where evidence gave him substantial grounds to believe the accused may have been legally insane when the alleged offence was committed.
The accused, Sean Redmond, had pleaded guilty in July 2003 at Castlebar Circuit Criminal Court to causing serious harm under section 4(1) of the Non-Fatal Offences Against the Person Act 1997. The charge concerned an alleged knife attack on Liam Humber in Castlebar in November 2002. The case stated said the attack caused serious injuries and was unprovoked. It also recorded evidence that Redmond had a psychiatric history and had reportedly said he heard voices telling him to “get them”.
Before sentence, Haugh J. considered psychiatric reports and witness statements. He said he had substantial grounds to believe the accused may have been insane in law at the time of the alleged offence, and that a not guilty plea might be more appropriate. The case stated recorded that the guilty plea was motivated by practical considerations: the accused preferred a definite sentence to possible detention at the pleasure of the Government in the Central Mental Hospital.
The Supreme Court distinguished the question of a person’s fitness to plead from whether the person was legally insane at the time of the alleged offence. It said overriding a guilty plea could interfere with an accused person’s choice of defence and could carry serious consequences, including an inquiry into fitness to plead and possible involuntary commitment.
Justice Kearns said a judge would need to be satisfied that very exceptional circumstances had been demonstrated before actively second-guessing an accused person and their legal or medical advisers. He concluded that the case stated was not framed in such extreme terms. The Court therefore answered the question in the negative, in the manner suggested by Justice Geoghegan.
The judgment answered the legal question referred to the Supreme Court. It did not determine the accused’s sanity at the time of the alleged offence or impose a sentence.