McGuire v. Almy 1. Case Name: McGuire v. Almy (p. 25) 2. Court & Date: Supreme Judicial Court of Massachusetts, 1937 3. Procedural History: (p. 25) At trial, the defendant moved for a directed verdict on the ground that she was insane and, therefore, could not form the requisite intent needed for a valid assault and battery claim. 4. Questions Presented: (p. 25) Can an insane person form the requisite intent needed for a valid assault or battery claim? 5. Trigger Facts: (p. 25) The plaintiff, a registered nurse, was employed to take care of the defendant. The defendant was an insane person, although she “was in good physical condition.” For most of the time the plaintiff cared for the defendant, the plaintiff kept the defendant locked in her room. On one occasion, the defendant, while locked in her room, had a violent attack and tore apart the furniture in her room. When the plaintiff entered the defendant’s room to grab a furniture leg from the defendant, the defendant struck the plaintiff on the head with the furniture leg. The plaintiff suffered injuries as a result and brought an action against the defendant for assault and battery. 6. Plaintiff’s Argument: (pp. 26-27) The plaintiff argued that the defendant’s mental illness does not preclude a finding of intent necessary for an assault or battery claim. 7. Defendant’s Argument: (pp. 26-27) The defendant argued that she was not capable of forming intent necessary for an assault or battery claim because she was insane. 8. Rule: (p. 27) Where an insane person by his act does intentional damage to the person or property of another, he is liable for that damage in the same circumstances in which a normal person would be liable. This means that in so far as a particular intent would be necessary in order to render a normal person liable, the insane person, in order to be liable, must have been capable of entertaining that same intent and must have entertained it in fact. But the law will not inquire further into his peculiar mental condition with a view to excusing him if it should appear that delusion or other consequence of his affliction has caused him to entertain that intent or that a normal person would not have entertained it. 9. Reasoning: (p. 27) The court determined that a jury could find that the defendant was capable of entertaining and that she did, in fact, entertain intent to strike and injure the plaintiff, and that she acted upon that intent. Thus, as long as th4e defendant possessed the requisite intent, her insanity is not a defense to liability for assault and battery. 10. Holding: (pp. 26-27) An insane person can form the requisite intent needed for a valid assault or battery claim. 11. Main Takeaway: Mental illness does not negate intent. 12. Other Notes: (pp. 26-27) The test for whether a mentally ill person had intent is the same as for a person without mental illness: Did the person intend to cause the harmful or offensive contact (specific intent), or did the person carry it out with substantial certainty that the harmful or offensive contact would follow (general intent)?