Davis v. United States (1895)

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Davis v. United States

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Submitted October 30, 1895
Decided December 16, 1895
Full case nameDavis v. United States
Citations

160 U.S. 469 ( more )

16 S. Ct. 353; 40 L. Ed. 499; 1895 U.S. LEXIS 2370
Court membership
Chief Justice
Melville Fuller
Associate Justices
Stephen J. Field  · John M. Harlan
Horace Gray  · David J. Brewer
Henry B. Brown  · George Shiras Jr.
Howell E. Jackson  · Edward D. White
Case opinions
Majority Harlan, joined by unanimous

Davis v. United States, 160 U.S. 469 (1895), is a criminal case establishing that in a federal case, the prosecution bears the burden of proof of sanity if an insanity defense is raised. [1] :17 It is a common law ruling that sets precedent in federal court, but is not a constitutional ruling interpreting the United States Constitution, so does not preclude states from requiring defendants to prove insanity, even to the point of requiring defendants to prove insanity beyond a reasonable doubt, as in Leland v. Oregon (1951). [1] :17

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 his or her actions due to an episodic or persistent psychiatric disease at the time of the criminal act. This is contrasted with an excuse of provocation, in which defendant is responsible, but the responsibility is lessened due to a temporary mental state. It 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 themselves or to others.

Common law law developed by judges

In law, common law is that body of law derived from judicial decisions of courts and similar tribunals. The defining characteristic of “common law” is that it arises as precedent. In cases where the parties disagree on what the law is, a common law court looks to past precedential decisions of relevant courts, and synthesizes the principles of those past cases as applicable to the current facts. If a similar dispute has been resolved in the past, the court is usually bound to follow the reasoning used in the prior decision. If, however, the court finds that the current dispute is fundamentally distinct from all previous cases, and legislative statutes are either silent or ambiguous on the question, judges have the authority and duty to resolve the issue. The court states an opinion that gives reasons for the decision, and those reasons agglomerate with past decisions as precedent to bind future judges and litigants. Common law, as the body of law made by judges, stands in contrast to and on equal footing with statutes which are adopted through the legislative process, and regulations which are promulgated by the executive branch. Stare decisis, the principle that cases should be decided according to consistent principled rules so that similar facts will yield similar results, lies at the heart of all common law systems.

A constitutional ruling is a legal case in the United States in which the United States Supreme Court interprets the Constitution of the United States and makes a ruling that binds all states. It is contrasted with a common law case which sets precedent in federal cases, but is not binding in state cases.

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MNaghten rules Guideline governing legal pleas of insanity

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Leland v. Oregon, 343 U.S. 790 (1952), was a United States Supreme Court case in which the Court upheld the constitutionality of placing the burden of persuasion on the defendant when they argue an insanity defense in a criminal trial. This differed from previous federal common law established in Davis v. United States (1895), in which the court held that if the defense raised an insanity defense, the prosecution must prove sanity beyond a reasonable doubt, but Davis was not a United States constitutional ruling, so only limited federal cases, but not state cases. Oregon had a very high burden on defense, that insanity be proved beyond a reasonable doubt. At that time, twenty other states also placed the burden of persuasion on the defense for an insanity defense.

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References

  1. 1 2 Criminal Law - Cases and Materials, 7th ed. 2012, Wolters Kluwer Law & Business; John Kaplan, Robert Weisberg, Guyora Binder, ISBN   978-1-4548-0698-1,