Working on the jury charge for a trial where NGRI has been raised. I have the excellent Mental Defense book but I still have a question. My indictment has multiple counts for a lot of offenses. Where do I put the NGRI consideration? Does it follow after each count or is it more of a special finding paragraph after all of the counts saying if you found him guilty of A,B, or C next consider NGRI . . .

Thanks in advance!

Trial on this case is Tuesday and should last the week and possibly into the next week. Any suggestions on where to put the NGRI would be appreciated. I have McClungs and it looks like a seperate charging paragraph after the actual charge if I am reading correctly. However, McClungs seems to only consider single count indictments. I have a 5 count indictment and this is starting to look like a real bear.

Any help appreciated!

You could do separate charges labelled as (Cause #), Count I, etc.

Do you think I could do a single paragraph like the example in mental defense book saying

if you found the defendant guilty of either (list charges) as alleged in the indictment but find (list jury charge for finding insanity) then find defendant NGRI.

would that be sufficient? Seems it would avoid making charge too long and prevent some bad verdict return finding him guilty of some charges but NGRI of others.

What do you think?