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9 Crim. Def. 7 (1982)
The Vietnam Connection: Charles Heads' Verdict

handle is hein.journals/ciiafen9 and id is 7 raw text is: THE VIETNAM
CONNECTION: Wellborn Jack, Jr.
CHARLES HEADS'
VERDICT
Introduction
Not Guilty by Reason Of Insanity, the bailiff
read aloud the verdict. It was late Saturday night,
October 10, 1981 in Shreveport, Louisiana at the
conclusion of Charles Heads' second trial for First
Degree Murder. Four years of painful and painstak-
ing preparation had paid off. For myself, Charles,
and all members of the defense team, this was a peak
experience not easily come by or likely to be equalled
again.
For two weeks a lockup jury of twelve ordinary
citizens had listened with understanding to the evi-
dence and argument and made the connection between
(1) Post-Traumatic Stress Disorder, Delayed Type,
(2) Charles's behavior when he killed his brother-in-
law, and (3) Charles's experiences as a nineteen year
old Marine, ten years earlier in Vietnam. During
those two weeks Charles's jurors had come to know
him and share his nightmares, fears, frustrations,
hopes, and aspirations.
Since then, many people have asked me to set forth
in some detail what I believe are some of the more
important things that we did to obtain this verdict.
These things I set forth in this article in a very per-
sonal way. I do so with the dual hope that meritorious
defenses of other Vietnam veterans will have a greater
chance of success and also that the awesomeness of
the task will discourage the presentation of unmeri-
torious defenses.

The task was awesome. Victory would never have
been possible without the active assistance of a large
team of volunteers who unstintingly and often pain-
fully gave of their time, energy, and effort. Not the
least of these was Charles himself.
History of the Case
Shortly after midnight on August 22, 1977, Charles
Heads shot and killed his sister-in-law's husband
under circumstances accurately summarized by the
Louisiana Supreme Court as follows, 385 So.2d at
231:
Defendant, a resident of Houston, Texas,
traveled to Shreveport in search of his wife and
three children who had left the family home in
Houston [4 days before]. After unsuccessfully
deriving his wife's location from his wife's
mother, defendant called the Shreveport home
of his wife's sister. The sister's denial of knowl-
edge of his wife's whereabouts arose his suspi-
cion and defendant drove to her home though it
was nearing midnight. No answers were made to
his repeated knocks on the doors and windows.
Defendant then kicked in a door leading from
the carport, entered and found his sister-in-law's
husband at the end of the bedroom hall, armed
with a pistol.
Though the evidence is not clear as to the
precise moment when the shooting began, both
the victim's wife and defendant's wife testified
that defendant began firing his pistol shortly
after breaking into the house. The sister-in-law's
husband pleaded with defendant to stop shoot-
ing and leave their home. The sister-in-law's
husband informed the defendant that he, too,
was armed and did not want to be forced to
shoot him. Defendant continued firing his pistol
down the bedroom hallway until he had emptied
the pistol of bullets. Defendant then ran to his
car, retrieved a rifle from the trunk, and re-
turned, firing several blasts, one of which struck
the sister-in-law's husband in the eye, killing
him.
Trial in May of 1978 resulted in a verdict of Guilty
of First Degree Murder. After a death penalty hear-
ing, the jury recommended life imprisonment. The

CRIMINAL DEFENSE, page 7

Author's Note:
The unadorned facts of Charles's life are the pow-
erful stuff out of which high drama and real life are
made. An essential part of the trial was proving each
of these facts through reliable eye-witness testimony
and authenticated documentation. This we did. The
theory of relevancy which made this evidence admiss-
ible was provided by the insanity defense based on
PTSD.

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