Clark v. Arizona | |
---|---|
Argued April 19, 2006 Decided June 29, 2006 | |
Full case name | Eric Michael Clark v. State of Arizona |
Docket no. | 05-5966 |
Citations | 548 U.S. 735 ( more ) 126 S. Ct. 2709; 165 L. Ed. 2d 842 |
Case history | |
Prior | Defendant convicted, Coconino County Superior Court, Sept. 3, 2003; affirmed, Ariz. Ct. App., Jan. 25, 2005; review denied, Ariz., May 25, 2005; cert. granted, 126 S. Ct. 797 (2005). |
Holding | |
Due process does not prohibit Arizona's use of an insanity test stated solely in terms of the capacity to tell whether an act charged as a crime was right or wrong. The state could also constitutionally limit a defendant's evidence of mental defect to only what is relevant to that insanity test, even when mens rea is an element of the charged crime. Arizona Court of Appeals affirmed. | |
Court membership | |
| |
Case opinions | |
Majority | Souter, joined by Roberts, Scalia, Thomas, Alito; Breyer (except Parts III–B and III–C and ultimate disposition) |
Concur/dissent | Breyer |
Dissent | Kennedy, joined by Stevens, Ginsburg |
Laws applied | |
U.S. Const. amend. XIV; Ariz. Rev. Stat. § 13-502(A) |
Clark v. Arizona, 548 U.S. 735 (2006), is a United States Supreme Court case in which the Court upheld the constitutionality of the insanity defense used by Arizona.
The Court affirmed the murder conviction of a man with paranoid schizophrenia for killing a police officer.
The man had argued that his inability to understand the nature of his acts at the time that they were committed should be a sufficient basis for showing that he lacked the requisite mental state required as an element of the charged crime.
The Court upheld Arizona's restriction of admissible mental health evidence only to the issue of insanity and not to show that the defendant did not possess the required mental intent level necessary to satisfy an element of the crime. Evidence is admissible only to show that the defendant was insane at the time of the crime's commission.
In this case, the defendant knew right from wrong and so he could not qualify under Arizona's insanity defense.
The constitutionality of an insanity defense was questioned as well as whether a defendant has a Fourteenth Amendment due process right, unrelated to the insanity plea, to present the correct evidence on the mental state to counter the prosecution's evidence of criminal intent. [1]
In the case, Eric Clark shot and killed a police officer at a traffic stop because he believed his town in Arizona had been taken over by aliens. Clark, was diagnosed with paranoid schizophrenia and used the insanity defense to try to use his mental disorder as an excuse for the crime that he had committed.
The court did not believe that Clark's insanity defense was a justifiable defense, and he was sentenced to 25 years in prison. Throughout the court case, Clark presented an elaborate testimony describing his odd behavior a year prior to the incident. Among many other things, Clark believed that "aliens", some being government employees, were trying to hurt and kill him and that the only way to stop them was through death.
A psychiatrist testified that Clark has paranoid schizophrenia in which a patient has delusions that a person is against the patient and/or family. [2] The psychiatrist said that at the time of the shooting, Clark was incapable of deciding right from wrong and so was insane.
Before being tried again, he was committed to a mental institution for two years, and his belief in aliens was still present afterward, but he believed that they were no longer out to get him but had another mission. [3]
Arizona was represented by assistant attorney general Randall M. Howe. [4] Clark was represented by Colorado attorney David I Goldberg.
In a 5–4 decision, in favor of Arizona, the US Supreme Court decided that the Arizona court could limit the amount of evidence used to plea a person's sanity for a defendant's insanity defense. [5] [1] Justice Souter believed that having a defendant prove his insanity in order to justify they were unable to clearly think while committing the crime would disprove his claim for insanity because they were able to think clearly to prove they were insane. [1] The court cited the Arizona Supreme Court's decision in State v. Mott , which refused to allow a psychiatric testimony to invalidate a criminal's intent and to uphold that Arizona does not allow evidence of a mental illness to neutralize the mens rea of a crime. [6] Mens Rea is an element of criminal responsibility regarding whether or not there was intention or knowledge of wrongdoing while a crime was being committed. [7] The court also determined that due process does not require a State to use both areas of the M'Naughten insanity test. Rather, a State may adopt an insanity test that focuses solely on moral incapacity. [8]
Judges Ginsburg, Kennedy, and Stevens disagreed with the majority ruling of the court. Justice Breyer partially concurred and agreed with the Court's "basic categorization" of evidence related to insanity. Further, he acknowledged that a State may provide consideration of mental-disease "solely in conjunction with the insanity defense." However, he dissented from the majority's opinion and would change the case so that Arizona courts could determine whether state law is consistent.
In dissent, Justice Kennedy stated that it was not necessary for him to address Clark's due process challenge to Arizona's insanity test. Instead, he disagreed with the majority for limiting Clark's claim to evidentiary support on his insanity. He also believed the Mott Rule, which does not allow evidence for insanity to prove someone is not guilty, [8] to be unjust in the case as it is an exclusion of evidence, despite its credibility. [8]
There was no controversy that Clark had schizophrenia when he shot Officer Moritz. [3] There was no controversy either that Clark actually believed that there were aliens who were out to get him, as he hung fishing line in his room as "booby traps" as well as wind chimes on the doors and windows to warn him of intruders. [3] Lastly, Clark kept a bird in his car to warn him of different changes in air temperature, which he believed could lead to possible intruders.
There is some controversy on the reasons for Clark's actions on the night of the crime. For example, he was playing music in his car at high volume. The state believed that the music was meant to lure the officer to his vehicle with a nuisance offense, as Clark had mentioned to a friend that he wanted to shoot a cop. [3] The defense expert, Dr. Morentz, dismissed that theory and believed Clark was playing music loudly to "drown out" the voices in his head, a tactic common among people with paranoid schizophrenia. [3]
The state and the defense began again to agree after he was sent to jail. Clark called the prison guards aliens and refused to eat out of fear of being poisoned by aliens. [3]
Depending on the state, the insanity law places the burden of proof on the prosecution, which must prove that the defendant is not insane, or on the defense, which must prove that the defendant is insane. After the application of the insanity defense began, Jones v. United States permitted people acquitted due to insanity to be held in a mental hospital for a longer time to the one that they would be in prison, depending on the circumstances. [9] The courts also require for the subject in question to be able to withstand a trial or otherwise to be hospitalized until they are able to go to trial. Another way that a case regarding mental illness is handled is the verdict being "guilty but mentally ill." Then, the person is given a sentence but is offered psychiatric treatment while incarcerated or is taken to a mental hospital until the person is believed to be capable enough to be taken to a prison to serve the remainder of the sentence. [9]
The insanity defense has existed since the 12th century and is one of the most controversial but one of the least used criminal defense strategies. It claims that a criminal defendant should not be found guilty because of the defendant's insanity. A person who is insane is said to lack the understanding of the crime or the difference between right and wrong. Initially, the defense could be used only to pardon a criminal's sentence. The concept that one's insanity could avoid the sentence began in the 19th century in Isaac Ray's The Medical Jurisprudence of Insanity and the English M'Naughton Case.
In 1843, Daniel M'Naughton was diagnosed with paranoid schizophrenia and thought that he was being persecuted, causing him to shoot and kill Edward Drummond. [9] He was found not guilty on the grounds that he was insane at the time of his act. The public were outraged by the decision.
The rule states that every person is assumed to be sane and that to establish a ground of insanity, it must be proved that at the time of committing a crime, the criminal was acting due to a "defect of reason" [9] or mental illness, causing a lack of understanding the nature of the act. [9] The rule includes as a test of distinguishing whether or not a defendant can determine the difference between right and wrong.
One of the best known applications of the insanity defense was for John W. Hinckley, a man who attempted to assassinate Ronald Reagan in 1982. He was ultimately acquitted of his charges under the insanity defense. [9] The outrage after the court decision caused four states to eliminate the insanity defense: Montana, Utah, Idaho, and Kansas. [9]
In United States law, an Alford plea, also called a Kennedy plea in West Virginia, an Alford guilty plea, and the Alford doctrine, is a guilty plea in criminal court, whereby a defendant in a criminal case does not admit to the criminal act and asserts innocence, but accepts imposition of a sentence. This plea is allowed even if the evidence to be presented by the prosecution would be likely to persuade a judge or jury to find the defendant guilty beyond a reasonable doubt. This can be caused by circumstantial evidence and testimony favoring the prosecution, and difficulty finding evidence and witnesses that would aid the defense.
The insanity defense, also known as the mental disorder defense, is an affirmative defense by excuse in a criminal case, arguing that the defendant is not responsible for their actions due to a psychiatric disease at the time of the criminal act. This is contrasted with an excuse of provocation, in which the defendant is responsible, but the responsibility is lessened due to a temporary mental state. It is also contrasted with the justification of self defense or with the mitigation of imperfect self-defense. The insanity defense is also contrasted with a finding that a defendant cannot stand trial in a criminal case because a mental disease prevents them from effectively assisting counsel, from a civil finding in trusts and estates where a will is nullified because it was made when a mental disorder prevented a testator from recognizing the natural objects of their bounty, and from involuntary civil commitment to a mental institution, when anyone is found to be gravely disabled or to be a danger to themself or to others.
The M'Naghten rule(s) (pronounced, and sometimes spelled, McNaughton) is a legal test defining the defence of insanity, first formulated by House of Lords in 1843. It is the established standard in UK criminal law, and versions have also been adopted in some US states (currently or formerly), and other jurisdictions, either as case law or by statute. Its original wording is a proposed jury instruction:
that every man is to be presumed to be sane, and ... that to establish a defence on the ground of insanity, it must be clearly proved that, at the time of the committing of the act, the party accused was labouring under such a defect of reason, from disease of the mind, as not to know the nature and quality of the act he was doing; or if he did know it, that he did not know he was doing what was wrong.
Insanity, madness, lunacy, and craziness are behaviors caused by certain abnormal mental or behavioral patterns. Insanity can manifest as violations of societal norms, including a person or persons becoming a danger to themselves or to other people. Conceptually, mental insanity also is associated with the biological phenomenon of contagion as in the case of copycat suicides. In contemporary usage, the term insanity is an informal, un-scientific term denoting "mental instability"; thus, the term insanity defense is the legal definition of mental instability. In medicine, the general term psychosis is used to include the presence of delusions and/or hallucinations in a patient; and psychiatric illness is "psychopathology", not mental insanity.
In criminal law, diminished responsibility is a potential defense by excuse by which defendants argue that although they broke the law, they should not be held fully criminally liable for doing so, as their mental functions were "diminished" or impaired.
In criminal law, automatism is a rarely used criminal defence. It is one of the mental condition defences that relate to the mental state of the defendant. Automatism can be seen variously as lack of voluntariness, lack of culpability (unconsciousness) or excuse. Automatism means that the defendant was not aware of his or her actions when making the particular movements that constituted the illegal act.
Actual innocence is a special standard of review in legal cases to prove that a charged defendant did not commit the crimes that they were accused of, which is often applied by appellate courts to prevent a miscarriage of justice.
The Criminal Lunatics Act 1800 was an Act of the Parliament of Great Britain that required and established a set procedure for the indefinite detention of mentally ill offenders. It was passed through the House of Commons in direct reaction to the trial of James Hadfield, who attempted to assassinate King George III.
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process.
In criminal law, a mitigating factor, also known as an extenuating circumstance, is any information or evidence presented to the court regarding the defendant or the circumstances of the crime that might result in reduced charges or a lesser sentence. Unlike a legal defense, the presentation of mitigating factors will not result in the acquittal of a defendant. The opposite of a mitigating factor is an aggravating factor.
Bigby v. Dretke 402 F.3d 551, the U.S. Court of Appeals for the Fifth Circuit heard a case appealed from the United States District Court for the Northern District of Texas on the issue of the instructions given to a jury in death penalty sentencing. The decision took into account the recent United States Supreme Court decisions concerning the relevance of mitigating evidence in sentencing, as in Penry v. Lynaugh.
Settled insanity is defined as a permanent or "settled" condition caused by long-term substance abuse and differs from the temporary state of intoxication. In some United States jurisdictions "settled insanity" can be used as a basis for an insanity defense, even though voluntary intoxication cannot, if the "settled insanity" negates one of the required elements of the crime such as malice aforethought. However, U.S. federal and state courts have differed in their interpretations of when the use of "settled insanity" is acceptable as an insanity defense and also over what is included in the concept of "settled insanity".
In the field of criminal law, there are a variety of conditions that will tend to negate elements of a crime, known as defenses. The label may be apt in jurisdictions where the accused may be assigned some burden before a tribunal. However, in many jurisdictions, the entire burden to prove a crime is on the prosecution, which also must prove the absence of these defenses, where implicated. In other words, in many jurisdictions the absence of these so-called defenses is treated as an element of the crime. So-called defenses may provide partial or total refuge from punishment.
Fault, as a legal term, refers to legal blameworthiness and responsibility in each area of law. It refers to both the actus reus and the mental state of the defendant. The basic principle is that a defendant should be able to contemplate the harm that his actions may cause, and therefore should aim to avoid such actions. Different forms of liability employ different notions of fault, in some there is no need to prove fault, but the absence of it.
Jones v. United States, 463 U.S. 354 (1983), is a United States Supreme Court case in which the court, for the first time, addressed whether the due process requirement of the Fourteenth Amendment allows defendants, who were found not guilty by reason of insanity (NGRI) of a misdemeanor crime, to be involuntarily confined to a mental institution until such times as they are no longer a danger to themselves or others with few other criteria or procedures limiting the actions of the state.
The Double Jeopardy Clause of the Fifth Amendment to the United States Constitution provides: "[N]or shall any person be subject for the same offence to be twice put in jeopardy of life or limb..." The four essential protections included are prohibitions against, for the same offense:
Insanity in English law is a defence to criminal charges based on the idea that the defendant was unable to understand what he was doing, or, that he was unable to understand that what he was doing was wrong.
United States federal laws governing offenders with mental diseases or defects provide for the evaluation and handling of defendants who are suspected of having mental diseases or defects. The laws were completely revamped by the Insanity Defense Reform Act in the wake of the John Hinckley Jr. verdict.
Hendershott v. People, Supreme Court of Colorado, 653 P.2d. 385 (1982), is a criminal case that a defendant who was not excused by being legally insane, might still be exculpated because he lacked a guilty mind due to a mental disease.
Kahler v. Kansas, 589 U.S. ___ (2020), is a case of the United States Supreme Court in which the justices ruled that the Eighth and Fourteenth Amendments of the United States Constitution do not require that states adopt the insanity defense in criminal cases that are based on the defendant's ability to recognize right from wrong. It was argued on October 7, 2019 and decided on March 23, 2020.