State of Iowa v. Yemissi Nadege Keto

CourtListener 10612743Iowactapp18 giu 2025

Testo completo

IN THE COURT OF APPEALS OF IOWA

No. 24-0916
Filed June 18, 2025

STATE OF IOWA,
Plaintiff-Appellee,

vs.

YEMISSI NADEGE KETO,
Defendant-Appellant.
________________________________________________________________

Appeal from the Iowa District Court for Dallas County, Thomas P. Murphy,

Judge.

A defendant appeals her convictions for first-degree murder and child

endangerment resulting in death. AFFIRMED.

Jessica Donels of Parrish Kruidenier, L.L.P., Des Moines, for appellant.

Brenna Bird, Attorney General, and Katherine Wenman, Assistant Attorney

General, for appellee.

Heard at oral argument by Schumacher, P.J., and Buller and Sandy, JJ.
2

SCHUMACHER, Presiding Judge.

Following the death of her one-year-old son, Yemissi Keto appeals her

convictions for first-degree murder and child endangerment resulting in death.

Keto claims the district court erred by excluding evidence of domestic abuse as it

relates to her insanity defense. Keto also challenges the sufficiency of the

evidence for her convictions. Upon review, we affirm.

I. Background Facts & Proceedings

On the morning of August 31, 2023, officers from the Waukee Police

Department responded to a 911 call from Keto. The dispatch was issued for an

“unknown problem.” Officers were informed “the caller was possibly sick and

vomiting and was requesting an ambulance.” Keto met officers at her front door.

As they entered the home, the officers noticed a strong smell of bleach. Keto was

struggling to speak and appeared distraught. Officers asked what was going on,

and Keto responded, “my son.” She directed the officers upstairs, where her

thirteen-month-old son, D.K., was located, unconscious and not breathing.

Officers found D.K. in a diaper on the floor, face up, and without a pulse.

Open containers of cleaning products were strewn upstairs. The floor surrounding

D.K. was “very wet and saturated” with what officers would later determine was

bleach. Sputum observed around D.K.’s mouth smelled of bleach. Although D.K.

was cold to the touch and slightly stiff, responders performed life saving measures.

Their efforts produced no signs of life. Responders ceased life-saving measures

roughly twenty-five minutes later. D.K. was pronounced dead at the scene.

Meanwhile, officer Chris Kickbush, who was located downstairs, and Stevi

Bundy, a mental-health professional serving as an emergency responder for the
3

Waukee Police Department’s crisis intervention team (CIT), spoke with Keto to

gather information about what had occurred.1 Keto was exhibiting signs of physical

distress, sweating profusely, and often grabbing her throat. She also appeared to

have a slight language barrier. But Keto could answer questions in English about

D.K.’s name, date of birth, and how long she had lived in the home. She elaborated

when asked about her husband, his work as an over-the-road truck driver, his

whereabouts at the time, and her relationship with him.

At multiple points after emergency responders had arrived, Keto said “drink”

or “drinking” with nothing further. She denied that she had been drinking alcohol.

Keto began coughing and spitting up into a bowl as Officer Kickbush and Bundy

talked with her. Bundy noticed her spit-up had a chemical smell. Eventually, Keto

was asked directly whether she drank bleach. Keto responded, “Yes.” Bundy

asked Keto “if she gave her child bleach that morning,” and Keto responded, “Yes.”

Approximately fifteen minutes had passed between the time Bundy and

Officer Kickbush began talking with Keto and when she disclosed the involvement

of bleach that morning. Only after Keto said she drank bleach did she inform

officers that she speaks French as a primary language.

Shortly thereafter, Keto was taken by ambulance for medical treatment.

Keto had “significant amounts of swelling in her mouth and in her airway.” Given

the information that Keto had consumed bleach, hospital staff was concerned the

swelling would continue to the point Keto would no longer be able to breathe. She

1 The 911 call that prompted the police dispatch did not indicate a need for a CIT

response. Officer Kickbush and Bundy responded because they were near the
dispatch location when the dispatch call was issued.
4

was intubated and sedated accordingly. She remained intubated and sedated until

September 2. At the recommendation of hospital staff, officers waited for more

than twenty-four hours after the sedatives were discontinued and Keto’s breathing

tube was removed before interviewing Keto.

On September 3, Detective Bryan Levsen spoke with Keto using an

interpreter, Officer Tolidji Hogbonouto. Keto stated that she wanted to die when

she drank the bleach on August 31. She confirmed that “the bleach bottles and

the containers of cleaning product that were consumed were kept in

a . . . cupboard upstairs next to [D.K.’s] bedroom; and they had a lid on them, and

that lid was unable to be opened by [D.K.]” She did not remember the answers to

some of Detective Levsen’s questions. At the end of the interview, Detective

Levsen provided Keto his business card in case she wanted to talk further.

On September 4, Keto began talking to an officer who sat watch outside of

her hospital room. Keto spoke with the officer in English and did not request a

translator. Keto told the officer, “I put cleaning stuff on his face. . . . And the name

is [D.K.]” Keto acknowledged, “[D.K.] died.” When asked if she knew how D.K.

died, Keto responded, “I put cleaning stuff in his face.”

After Keto spoke to the officer on watch, Detective Levsen returned per

Keto’s request. Officer Hogbonouto translated. Keto admitted to drinking bleach

in a suicide attempt. She stated she held D.K. down in the spot where emergency

responders found him and poured a cleaner over his face because she did not

want to leave him behind after she left. She admitted that when the cleaner did

not cause D.K. to lose consciousness she held her hand over D.K.’s nose and

mouth. After D.K. stopped breathing, Keto drank more bleach. She remembered
5

calling her brother after D.K. stopped breathing but did not remember how long

after these events she called the police.

On September 5, Keto was transferred to the University of Iowa’s medical

psychiatry unit. There, she exhibited symptoms of tactile, visual, and auditory

hallucinations.

The State charged Keto with first-degree murder, a class “A” felony in

violation of Iowa Code section 707.2(1)(e) (2023), and child endangerment

resulting in death, a class “B” felony in violation of Iowa Code section 726.6(1)(a)

and (b). Keto asserted she was not guilty by reason of insanity.

Prior to trial, the State filed a motion in limine to exclude evidence of alleged

domestic abuse between Keto and her husband. A hearing on the motion was

held. The State argued the evidence was irrelevant and would risk confusing the

issues at trial. Keto countered by arguing the evidence was relevant to her insanity

defense and that it should be admissible to impeach Keto’s husband if he denied

being abusive or violent during trial testimony. In a written ruling on the motion,

the district court ruled:

Prior bad acts by the defendant’s spouse: Granted. This involves
alleged domestic abuse. If he is a witness, such evidence cannot be
used to impeach or attack the credibility of the spouse. But the
defendant claims that the evidence is relevant to her insanity
defense. Deposition transcripts provided by the parties indicate that
trauma may be relevant. For now, the motion is granted. But the
defendant may make an offer of proof at trial if there is proper
foundation.

(Emphasis added.)

Three expert witnesses testified at trial: Dr. Andrea Weber and Dr. Steven

Bruce on Keto’s behalf and Dr. Rosanna Jones-Thurman for the State. Dr. Weber,
6

a clinical associate professor in psychiatry and internal medicine, diagnosed Keto

with severe major depressive disorder with psychosis. Dr. Bruce, a clinical

psychologist and professor of psychological sciences, diagnosed Keto with

postpartum psychosis and significant major depression. Dr. Jones-Thurman, a

forensic and clinical psychologist, disagreed with both diagnoses as they related

to the events of August 31.

A jury convicted Keto on both counts.2 Keto appeals.

II. Evidentiary Challenge

Keto challenges the district court’s exclusion of evidence of her husband’s

alleged domestic abuse against her. The State argues the court’s “preliminary

ruling” about this evidence “did not preserve Keto’s argument on appeal.” We

agree.

“It is a fundamental doctrine of appellate review that issues must ordinarily

be both raised and decided by the district court before we will decide them on

appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002).

A ruling sustaining a motion in limine is generally not an evidentiary
ruling. Rather, a ruling sustaining a motion in limine simply adds a
procedural step to the introduction of allegedly objectionable
evidence. Thus, a motion in limine . . . , if sustained, excludes
reference or introduction of this evidence until its admissibility is
determined by the trial court, outside the presence of a jury, in an
offer of proof.

Quad City Bank & Tr. v. Jim Kircher & Assocs., P.C., 804 N.W.2d 83, 89 (Iowa

2011) (internal citations omitted). Thus, when a motion in limine is sustained, an

offer of proof at trial is generally required to preserve error. State v. Thoren, 970

2 For the purposes of sentencing, Keto’s convictions merged.
7

N.W.2d 611, 621 (Iowa 2022). But if the “ruling reaches the ultimate issue and

declares the evidence admissible or inadmissible, it is ordinarily a final ruling and

need not be questioned again during trial.” State v. O’Connell, 275 N.W.2d 197,

202 (Iowa 1979).

Keto argues the written ruling was final and so error is preserved. She relies

on analogy to the facts of State v. Alberts, 722 N.W.2d 402 (Iowa 2006). In Alberts,

the State filed a motion in limine to determine the admissibility of evidence under

Iowa’s rape-shield law. 722 N.W.2d at 406. The defendant filed a resistance,

accompanied by an offer of proof. Id. at 406–07. In its oral ruling, the district court

stated it would not permit the disputed evidence but noted that if the corresponding

witness opened the door, the disputed evidence may become admissible. Id. at

407. The supreme court found the district court’s admissibility ruling was

“definitive” and the defendant was not required to take further action at trial to

preserve error. Id.

We are unpersuaded by the parallels Keto suggests between the facts of

Alberts and the facts here. First, the Alberts ruling was made after a pre-trial offer

of proof and after the defendant submitted “three separate briefs outlining the law

surrounding the admissibility of such evidence.” Id. at 406–07. In contrast, Keto

does not point us to any offer of proof in briefing submitted in support of her position
8

on the issue.3 Rather, Keto’s resistance to the motion appears in the record before

us only in the transcript of the motion hearing.4

The arguments from both sides concerning the disputed evidence, including

arguments on its use for impeachment—which is not at issue on appeal—cover a

collective two pages of double-spaced hearing transcript. Keto argued “domestic

abuse and violence issues between [Keto’s husband] and [Keto] are relevant to

the insanity defense,” and that “both Dr. Weber and Dr. Bruce consider the

abuse . . . a major contributing factor to her insanity.” The State countered that

there is no clear proof that the alleged abuse occurred, as required for “prior bad

act evidence, which this would be, to be admitted.” In short, we decline to conclude

this brief discussion amounted to “a full opportunity to argue the merits of their

respective positions,” as the Alberts court determined occurred. Id. at 407.

Keto also claims the district court’s ruling and the ruling in Alberts both

definitively determined the disputed evidence was inadmissible but conditional.

The ruling in Alberts was only conditional upon the victim’s trial testimony; the

district court commented that inadmissible evidence about the victim’s character

could become admissible if the victim “open[ed] the door.” Id. On appeal, the

supreme court explained, “[e]ven though the district court stated the evidence may

3 The written ruling mentions deposition transcripts that “indicated that trauma may

be relevant.” The only deposition transcripts included in our record on appeal were
submitted in support of a motion in limine over a separate evidentiary dispute. Keto
does not provide a citation to any pre-trial offer of proof on the issue on the
admissibility of evidence of domestic abuse.
4 Four motions in limine were filed within the month before the recorded hearing,

two from each party. The State filed resistance to Keto’s first motion in limine. No
resistance filing by Keto appears in the record before us in response to either of
the State’s motions in limine.
9

become admissible if R.M. opened the door to her virtue, this does not change the

fact that the court’s ruling was controlling so long as this door was not opened.”

Id.; see also 7 Laurie Kratky Doré, Iowa Practice Series: Evidence § 5.412:1

(2024–2025 ed. 2024) (recognizing inadmissible evidence about a victim’s sexual

history may become admissible for impeachment purposes in a criminal trial).

In contrast to Alberts, this is not a situation where the ruling recognized that

the admission of certain evidence may overcome the court’s denial of the

admissibility of certain other evidence. The “condition” placed here on the

evidence’s admissibility was a requirement that Keto make an offer of proof at

trial—generally, the procedural step to preserve error after a ruling on a motion in

limine. See Quad City Bank & Tr., 804 N.W.2d at 89. We are unconvinced that

the limine rulings are equally definitive.

As we noted in State v. Curtis, No. 22-1069, 2023 WL 4104116, at *4 (Iowa

Ct. App. June 21, 2023), “the words of the district court must be given due

consideration to evaluate the unequivocal intent of the ruling.” See also Alberts,

722 N.W.2d at 406 (“The key to our analysis is to determine what the trial court

ruling purported to do.”). In its ruling, the district court recognized that evidence of

domestic abuse could be relevant to Keto’s insanity defense and stated the State’s

motion was granted “for now.” The next sentence invited Keto to “make an offer

of proof at trial if there is proper foundation.” “Because that language can mean

the ruling could be reconsidered at a later time during the trial, the ruling was not

unequivocal.” Curtis, 2023 WL 4104116, at *4.

Another parallel Keto attempts to draw is that “both parties treated the

court’s ruling on the motion as a final decision.” Alberts, 722 N.W.2d at 407. In
10

support of this parallel, Keto points to two moments in trial where witness

examination either touched on the disputed evidence or approached the subject

matter. The first instance occurred during the State’s examination of a witness.

After a brief discussion off the record, the State ceased its line of questioning and

moved on. In the second instance, Keto asked Dr. Jones-Thurman about the

disputed evidence—specifically asking whether it alluded to marital “abuse”—

without objection. Keto asked three more questions before the State objected,

which was sustained and followed by another brief discussion off the record.

Keto also points to the State’s statements following the close of evidence.

In context, the identified statements made by the State are less about affirmatively

contending it was prohibited from presenting the excluded evidence, as Keto

characterizes it, and more about proactively addressing the possibility that Keto

might argue in closing “that the State has somehow concealed some important

evidence.” To show the possibility existed, the State referenced Keto’s

examination of Dr. Jones-Thurman, noted above, and “other questions elicited by

the defense to other witnesses about [the disputed evidence].” On balance, if

these three moments are not contrary to Keto’s argument about treating the ruling

as final, they are at least not the support she proposes.

We are unconvinced by Keto’s attempts to analogize the facts here to

Alberts. Unlike in Alberts, as noted by the State at oral arguments, Keto “held all

the cards” at trial with regard to making an offer of proof concerning this evidence.

The written ruling was not unequivocal—it indicated the district court was willing to

reconsider its ruling on the evidence as it related to her insanity defense if Keto
11

made an offer of proof at trial.5 But Keto never made this offer of proof. Thus,

error was not preserved.

III. Sufficiency of the Evidence

A. Standard of Review

“We review the sufficiency of the evidence for correction of errors at law.”

State v. Crawford, 972 N.W.2d 189, 202 (Iowa 2022) (quoting State v. Buman, 955

N.W.2d 215, 219 (Iowa 2021)). We are bound by a jury verdict supported by

substantial evidence. Id.

Substantial evidence is evidence sufficient to convince a rational trier
of fact the defendant is guilty beyond a reasonable doubt. In
determining whether the jury’s verdict is supported by substantial
evidence, we view the evidence in the light most favorable to the
State, including all “legitimate inferences and presumptions that may
fairly and reasonably be deduced from the record evidence.”

Id. (internal citations omitted) (quoting State v. Tipton, 897 N.W.2d 653, 692 (Iowa

2017)). When applying this analysis, “[w]e consider all evidence, not just the

evidence supporting the conviction.” State v. Ernst, 954 N.W.2d 50, 54 (Iowa

2021).

A defendant who raises an insanity defense holds the burden of proof. Iowa

Code § 701.4. The defendant must prove insanity at the time of the offense by a

preponderance of the evidence. Id.

B. Corroboration of Keto’s Statements on September 3

Keto argues her statements on September 3 were not sufficiently

corroborated for the jury to rely on them. She concedes certain “portions of [her]

5 We need not opine on the finality of the ruling for the purposes of impeachment

as Keto does not fault the district court for prohibiting impeachment with the
disputed evidence.
12

confession were corroborated,” but she claims there was no corroboration for any

statement that she harmed D.K. with an “understanding [of] the nature and quality

of her actions and [an] appreciati[on of] the difference between right and wrong.”

“The general rule is that a confession standing alone will not warrant a

criminal conviction unless other proof shows the defendant committed the crime.”

State v. Polly, 657 N.W.2d 462, 466 (Iowa 2003); see also Iowa R. Crim. P. 2.21(4).

“Corroborating evidence may be either direct or circumstantial. It need not be

strong evidence, ‘nor need it go to the whole of the case so long as it confirms

some material fact connecting the defendant with the crime.’” State v. Meyers,

799 N.W.2d 132, 139 (Iowa 2011) (internal citation omitted) (quoting State v.

Liggins, 524 N.W.2d 181, 187 (Iowa 1994)). The point of corroborating evidence

is not to provide independent proof beyond a reasonable doubt that the crime

occurred, but rather it is to fortify the truth of the admissions. Polly, 657 N.W.2d at

467.

Keto begins her argument with the proposition that “[c]orroboration is

particularly important here, where the defendant raises an insanity defense.” We

discern no indication from the legal authority she provides that a defendant’s

assertion of the insanity defense alters our usual corroboration analysis. See

generally Polly, 657 N.W.2d 462; State v. Hobson, 284 N.W.2d 239 (Iowa 1979);

Escobedo v. Illinois, 378 U.S. 478 (1964); Opper v. United States, 348 U.S. 84

(1954). To the extent that she is arguing the insanity defense requires a higher

standard for a court to find sufficient corroborative evidence, her lack of supportive

legal authority waives the argument. See Iowa R. App. P. 6.903(2)(a)(8)(3).
13

On September 3, the date of the confession in dispute, Keto admitted to

drinking bleach and disclosed that D.K. also drank bleach. Keto also admitted

these acts on August 31 to Bundy and on September 4 to the officer outside her

hospital room and again to Detective Levsen. These statements were

corroborated by the chemical smell of Keto’s vomit, her body’s physical reaction

that required intubation at the hospital, the strong chemical odor throughout the

house, D.K.’s sputum that smelled like bleach around his mouth, and the bleach-

soaked carpet surrounding D.K. when emergency responders arrived. Given

these facts, Keto’s confession on September 3 was supported by enough other

evidence for a jury to be justified in believing Keto’s statements were true.

Keto admitted to smothering D.K. on September 4. Keto’s argument on

appeal does not challenge the reliability of her statements made in the September

4 interview with Detective Levsen. But to be sure, the State presented evidence

to corroborate these statements too. D.K. had injuries on both sides of his nose

near his nostrils that the autopsy examiner testified would not be caused during

life-saving measures. An injury on the inside of his lip suggested pressure had

been applied “on the outside of the lip, pushing that lip down on the tooth.” D.K.’s

cause of death was suffocation. And no one else was present in the home on

August 31; Keto was the only person who could have caused these injuries. See

State v. Vargas, No. 23-0422, 2024 WL 707295, at *4 (Iowa Ct. App. Feb. 21,

2024) (considering opportunity as a corroborating factor). Again, based on the

evidence presented, the jury was justified in believing Keto’s statements on

September 4 were true.
14

C. Insanity Defense

Keto also argues she should not have been convicted because she proved

her insanity defense.

The jury was instructed that to find Keto not guilty by reason of insanity,

Keto was required to prove by a preponderance of the evidence that “[a]t the time

the crime was committed, Ms. Keto suffered from such a diseased or deranged

condition of the mind as to render her incapable of” either: (1) “knowing the nature

and quality of the acts she is accused of,” or (2) “distinguishing between right or

wrong in relation to the act.” The jury was also instructed, “To know and

understand the nature and quality of one’s acts means a person is mentally aware

of the particular acts being done and the ordinary and probable consequences of

them.”

“[A]n insanity defense often comes down to a ‘battle of the experts’. . . .”

State v. Martin, No. 23-0454, 2024 WL 2842318, at *3 (Iowa Ct. App. Jun. 5, 2024)

(quoting State v. Wadsworth, No. 16-1775, 2018 WL 2230666, at *8 (Iowa Ct. App.

May 16, 2018)). In such cases, the roles of the fact finder at trial and reviewing

courts on appeal are as follows:

When conflicting psychiatric testimony is presented to the fact
finder, the issue of sanity is clearly for the fact finder to decide. The
trial court as trier of fact is not obligated to accept opinion evidence,
even from experts, as conclusive. When a case evolves into a battle
of experts, we, as the reviewing court, readily defer to the district
court’s judgment as it is in a better position to weigh the credibility of
the witnesses.

State v. Jacobs, 607 N.W.2d 679, 685 (Iowa 2000) (internal citations omitted).

Keto presented two expert witnesses in her defense. Dr. Weber testified

she believed Keto was suffering from psychological difficulties at the time that D.K.
15

died. When asked her opinion on whether Keto “was capable of knowing and

understanding the nature and quality of her actions” on August 31, Dr. Weber

responded, “I believe she was severely depressed for months.” She then

expressed doubts that the psychosis she had diagnosed Keto with had developed

in six days following D.K.’s death.

Dr. Bruce testified he believed that on August 31 Keto was suffering from

psychological difficulties, “not able to . . . form a specific intent,” and not capable

of distinguishing between right and wrong. Dr. Bruce testified regarding the factors

he considered in forming this belief. He explained what signs and symptoms Keto

presented before August 31 that are commonly reported by individuals

experiencing psychosis, such as lack of sleep, nightmares, and headaches. After

August 31, Keto also displayed signs of tactile, auditory, and visual

hallucinations—symptoms Dr. Bruce explained were “consistent . . . with

psychosis for sure.”

The State presented expert testimony from Dr. Jones-Thurman, who

disagreed that on August 31 Keto was unable to differentiate right from wrong or

was unable to understand the nature and consequences of her actions. She based

this opinion on Keto’s decision to call 911 and her brother after D.K. stopped

breathing, Keto’s ability to communicate with emergency responders, and Keto’s

statement to officers in the days following August 31 that “she knew what she did

was bad.”

Dr. Jones-Thurman also disagreed that Keto was suffering from postpartum

depression or postpartum psychosis. On postpartum psychosis, Dr. Jones-

Thurman explained,
16

It’s very rare. It occurs in one or two out of one thousand child-
bearing women within the first two to four weeks after delivery. And
the onset is rapid, sometimes as early as two or three days after
childbirth.
....
[H]omicidal behavior rarely [occurs] in women who have postpartum
psychosis.

She also explained, psychosis is generally not a state of mind that one would

experience “acute[ly] and then kind of stop and come back [from],” with the

exception of specific circumstances not relevant here. Prior to August 31, Keto

had no diagnoses of postpartum depression and there was no indication anyone

had noticed Keto experiencing hallucinations, delusions, paranoia, or abnormal

thoughts or speech patterns. Dr. Jones-Thurman also found it telling that there

was no “collateral evidence” of psychosis, such as a house in disarray, neglect of

personal hygiene, excessive retail spending, or substance abuse.

On appeal, Keto counters that “all the cited pieces of evidence have other,

competing inferences that can be drawn from them.” Even so, “this is not a case

where proof of [sanity] depends upon a single piece of evidence from which two

reasonable inferences could be drawn.” State v. Keeton, 710 N.W.2d 531, 535

(Iowa 2006). The evidence contained conflicting expert testimony, and it was the

jury’s role to weigh the experts’ credibility and make findings of fact accordingly.

See Jacobs, 607 N.W.2d at 685.

In addition to her experts’ testimony, Keto argues the evidence presented

raises reasonable inferences that she was legally insane on August 31. But she

does not explain how the evidence overcame the presumption of sanity, which the

jury was instructed applied here. And a jury is free to reject a defendant’s
17

interpretation of the evidence presented. State v. Jones, 967 N.W.2d 336, 343

(Iowa 2021).

Keto’s actions, admissions, and testimony, and the reasonable inferences

available from them, are sufficient for a reasonable jury to credit

Dr. Jones-Thurman’s testimony rather than testimony from Keto’s expert

witnesses. Detective Levsen testified that on September 4 Keto explained to him

why she poured bleach on D.K. and suffocated him. Keto planned to kill herself

and did not want to leave D.K. behind. Detective Levsen asked Keto if she

suffocated [D.K.] “because the bleach wasn’t causing him to pass out?” Keto

responded, “Yes.” The jury watched the footage of Detective Levsen’s body cam

which captured this conversation. In sum, the jury could reasonably conclude that

Keto was mentally aware of the ordinary and probable consequences of her acts

of pouring bleach on D.K.’s face and of obstructing his mouth and nose with her

hand—that D.K.’s death would result.

“[I]t is not for us to interfere with the finding made when supported by

substantial evidence, even though the evidence may have also supported a finding

favorable to the defendant.” Keeton, 710 N.W.2d at 535. Because it was

reasonable for the jury to accept Dr. Jones-Thurman’s expert opinion over the

opinions of Keto’s experts, substantial evidence supports the jury’s conclusion that

Keto failed to prove her insanity defense.

IV. Conclusion

Because Keto did not make an offer of proof at trial on the evidentiary

challenge she now raises, error is not preserved. Corroborative evidence of Keto’s
18

confession exists in the record to support the guilty verdicts. And the jury was free

to reject Keto’s insanity defense based on the expert testimony presented at trial.

AFFIRMED.

Continua la tua ricerca in ChatGPT o Claude

Collega Omnilex per cercare nel corpus legale dal tuo assistente IA.