Kangas v. State

CRIMINAL LAW

Matthew Naiman

In Kangas v. State, the court of appeals held that judges may instruct a jury that mental state may be inferred from circumstantial evidence. A jury convicted Kangas to two 99-year consecutive sentences for the intentional killing of two state troopers whom he knew to be acting in performance of their duties. The judge instructed the jury that the State could use Kangas’s actions as circumstantial evidence to infer his mental state of culpability. Kangas challenged the instruction on the grounds that it allowed inference of mental state from actions and that the criminal code’s definitions of culpable mental states do not reference circumstantial proof. He further challenged the instruction as an improper judicial comment on the weight of the evidence. On appeal, the court of appeals held that the statutory definition of culpable mental states was intended to show what must be proved and that Alaska law makes no distinction between direct and circumstantial evidence. Had the legislature intended to restrict the allowable classes of evidence, it would have been explicit. Further, the court of appeals held that, while judges are prohibited from expressly or impliedly conveying their personal views on how the jury should rule, judges must inform juries of the law. The court of appeals found no evidence that the superior court judge provided a personal viewpoint; further, the court found that the instruction as a whole was a proper directive of the applicable law. Affirming the lower court’s decision, the court of appeals held that judges may instruct a jury that circumstantial evidence may be used to infer mental state.

Kangas v. State

CRIMINAL LAW

Matthew Naiman

In Kangas v. State, the court of appeals held that judges may instruct a jury that mental state may be inferred from circumstantial evidence. A jury convicted Kangas to two 99-year consecutive sentences for the intentional killing of two state troopers whom he knew to be acting in performance of their duties. The judge instructed the jury that the State could use Kangas’s actions as circumstantial evidence to infer his mental state of culpability. Kangas challenged the instruction on the grounds that it allowed inference of mental state from actions and that the criminal code’s definitions of culpable mental states do not reference circumstantial proof. He further challenged the instruction as an improper judicial comment on the weight of the evidence. On appeal, the court of appeals held that the statutory definition of culpable mental states was intended to show what must be proved and that Alaska law makes no distinction between direct and circumstantial evidence. Had the legislature intended to restrict the allowable classes of evidence, it would have been explicit. Further, the court of appeals held that, while judges are prohibited from expressly or impliedly conveying their personal views on how the jury should rule, judges must inform juries of the law. The court of appeals found no evidence that the superior court judge provided a personal viewpoint; further, the court found that the instruction as a whole was a proper directive of the applicable law. Affirming the lower court’s decision, the court of appeals held that judges may instruct a jury that circumstantial evidence may be used to infer mental state.