Kahler v. Kansas

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Kahler v. Kansas
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued October 7, 2019
Decided March 23, 2020
Full case nameKahler v. Kansas
Docket no. 18-6135
Citations589 U.S. ( more )
140 S. Ct. 1021; 206 L. Ed. 2d 312
Argument Oral argument
Case history
PriorConviction affirmed, State v. Kahler, 307 Kan. 374, 410 P.3d 105 (Kan. 2018); cert. granted, 139 S. Ct. 1318 (2019).
Holding
The due process clause of the United States Constitution does not require states to adopt a definition of the insanity defense that turns on whether the defendant knew that his or her actions were morally wrong.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Neil Gorsuch  · Brett Kavanaugh
Case opinions
MajorityKagan, joined by Roberts, Thomas, Alito, Gorsuch, Kavanaugh
DissentBreyer, joined by Ginsburg, Sotomayor
Laws applied
U.S. Const. amend. VIII, XIV

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. [1] [2]

Contents

Background

Insanity defense

The insanity defense is a traditional affirmative defense that dates at least back to English common law. The codification of the M'Naghten rules, which have been referenced in one form or another in US law as well as UK law, indicates that someone may be found not guilty of a crime because of a mental condition which prevents them from either controlling their actions or from knowing whether their actions were right or wrong.

Legislative activity

In 1995, the state of Kansas passed a law (Kan. Stat. Ann. § 22-3220) which revoked the traditional insanity defense. Defendants could no longer argue that, because of their mental illness, they were incapable of deciding right from wrong. Instead, defendants with mental illness were only permitted to argue that their mental illness prevented them from forming the specific intent (or mens rea) needed to commit the crime. [3] Supreme Court Justice Stephen Breyer described the distinction between the two systems in his dissent in Delling v. Idaho, a case covering the same topic that the Supreme Court declined to hear in 2012: [4] [5]

Case One: The defendant, due to insanity, believes that the victim is a wolf. He shoots and kills the victim.

Case Two: The defendant, due to insanity, believes that a wolf, a supernatural figure, has ordered him to kill the victim.

In Case One, the defendant does not know he has killed a human being, and his insanity negates a mental element necessary to commit the crime. In Case Two, the defendant has intentionally killed a victim whom he knows is a human being; he possesses the necessary mens rea.

In both cases the defendant is unable, due to insanity, to appreciate the true quality of his act, and therefore unable to perceive that it is wrong. But … the defendant in Case One could defend the charge by arguing that he lacked the mens rea, whereas the defendant in Case Two would not be able to raise a defense based on his mental illness. [4]

As of 2020, at least four other states have passed laws which are conceptually similar to Kansas's: Idaho, Alaska, Utah, and Montana [6]

Kahler murder case

In late 2009, James Kahler was arrested and charged with four counts of first-degree murder with the murder of four members of his family: his wife, his wife's grandmother, and his two teenage daughters.

During his trial, his defense argued that he had mentally 'snapped' following his divorce and job loss. [7] At the time of the murder, they asserted that he suffered from depression [7] and had an obsessive-compulsive, narcissistic, and histrionic personality. [5] The prosecution rebutted the defense's psychiatric testimony with an expert psychiatrist of its own. The prosecution's psychiatrist conceded that Kahler indeed suffered from clinical depression but argued that he was still capable of planning the murders. [8]

Despite this testimony, he was found guilty of each murder and sentenced to death at the end of August 2011. [9] An Osage County judge issued a death warrant for Kahler on October 11, 2011.

In lower courts

Under state law, capital murder cases can be appealed directly to the state supreme court. Accordingly, Kahler appealed his case to the Kansas Supreme Court, raising ten issues related to the conduct of the trial and actions taken by the judge and prosecutor. Two of these issues were the constitutionality of KSA 22–3220, the 1995 state law which abolished the traditional insanity plea and allowed defendants only the option of arguing that their mental illness prevented him from forming criminal intent, as well as the constitutionality of executing someone who currently suffers from a severe mental illness [10]

In a ruling, the Kansas Supreme Court rejected Kahler's appeals, noting its prior precedent in State v. Bethel (2003):

The same arguments made by Kahler were considered and rejected by this court in State v. Bethel, 275 Kan. 456, 66 P.3d 840 (2003). The Bethel court conducted a thorough review of the pertinent decisions of the United States Supreme Court and other states that had considered the issue. Ultimately, the Bethel court concluded that "K.S.A. 22-3220 does not violate the defendant's right to due process under the United States or Kansas Constitutions." 275 Kan. at 473; see State v. Searcy, 118 Idaho 632, 798 P.2d 914 (1990) (finding mens rea approach of state statute did not violate due process); State v. Korell, 213 Mont. 316, 690 P.2d 992 (1984) (same); State v. Herrera, 895 P.2d 359 (Utah 1995) (same). Kahler relies on Finger v. State, 117 Nev. 548, 569, 27 P.3d 66 (2001), in which the Nevada Supreme Court held legal insanity is a fundamental principle of the criminal law of this country. But the Bethel court considered and rejected the reasoning of the Nevada Supreme Court in Finger, and we adhere to our Bethel decision. [11]

The Kansas Supreme Court acknowledged that the judge had made errors in handling the case but did not deem these errors significant enough to warrant a new trial or to vacate Kahler's convictions or sentences. [10]

He then appealed his case to United States Supreme Court, which granted a writ of certiorari on March 28, 2019. [12] [13]

At issue in the case is whether the lack of an insanity defense violates the due process clause of the 14th Amendment and 8th Amendment. [5] [14]

At the Supreme Court

Sarah Schrup, the head of the Northwestern University School of Law Supreme Court practicum, argued the case before the Court on behalf of Kahler. Toby Crouse, the Kansas Solicitor General, argued the case on behalf of the state of Kansas. [15] Oral arguments were held in October 2019. Kahler v. Kansas was the first case that was heard during the October 2019 term.

Kahler's argument is that the M'Naghten rule represents the codification of a legal concept that goes back all the way to Medieval common law and should be considered part of the due process of law. [5] His argument asserts that, for centuries, defendants were held culpable only when they were able to distinguish between right and wrong and that people who were legally insane did not have the capacity to do so. [15] The state's argument emphasized the importance of federalism, allowing states the autonomy to make their own laws within the framework of the state and federal constitutions. The state also noted that the definition of insanity has varied in different ways throughout history and that one version (the M'Naghten rule) should not be viewed as an inherent aspect of due process. [5] [15]

Majority opinion

Justice Elena Kagan wrote the majority opinion which upheld Kansas's state law. [1] Kagan noted the need to refer back to eminent common-law authorities such as Blackstone, Coke, Hale, and others. [16] In the opinion, Kagan wrote that the Kansas law did not violate Kahler's fundamental right to due process, noting that definitions of legal culpability and mental illness have been traditionally reserved for the states. Kagan noted that, contrary to Kahler's argument before the court, Kansas had not in fact abolished the insanity defense but had instead simply modified it, which the Constitution has generally permitted. The opinion points out that Kahler could have still presented a mental illness defense at trial and could also have presented evidence during his sentencing hearing. [2] [17]

Dissent

Justice Stephen Breyer dissented from the majority opinion, joined by Justices Ruth Bader Ginsburg and Sonia Sotomayor. Breyer conceded that states do have broad leeway to define state crimes and criminal procedures, including the definitions and standards of the insanity defense. However, he argued that Kansas's law did not simply modify the insanity defense but had removed the core requirement of whether or not the defendant could distinguish from right and wrong. [2] Breyer's dissent was rooted in the centuries of tradition behind the original M'naghten Rule and noted that only a handful of states had modified it in the way that Kansas had.

Related Research Articles

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.

<span class="mw-page-title-main">M'Naghten rules</span> Guideline governing legal pleas of insanity

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.

In American jurisprudence, an excuse is a defense to criminal charges that is a distinct from an exculpation. Justification and excuse are different defenses in a criminal case. Exculpation is a related concept which reduces or extinguishes a person's culpability, such as their liability to pay compensation to the victim of a tort in the civil law.

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, irresistible impulse is a defense by excuse, in this case some sort of insanity, in which the defendant argues that they should not be held criminally liable for their actions that broke the law, because they could not control those actions, even if they knew them to be wrong. It was added to the M'Naghten rule as a basis for acquittal in the mid 20th century.

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.

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.

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.

<i>Bigby v. Dretke</i>

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".

Foucha v. Louisiana, 504 U.S. 71 (1992), was a U.S. Supreme Court case in which the court addressed the criteria for the continued commitment of an individual who had been found not guilty by reason of insanity. The individual remained involuntarily confined on the justification that he was potentially dangerous even though he no longer suffered from the mental illness that served as a basis for his original commitment.

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.

Indiana v. Edwards, 554 U.S. 164 (2008), was a United States Supreme Court case in which the Court held that the standard for competency to stand trial was not linked to the standard for competency to represent oneself.

<span class="mw-page-title-main">Insanity in English law</span> Defense strategy in English criminal law

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 v. Comstock, 560 U.S. 126 (2010), was a decision by the Supreme Court of the United States, which held that the federal government has authority under the Necessary and Proper Clause to require the civil commitment of individuals already in Federal custody. The practice, introduced by the Adam Walsh Child Protection and Safety Act, was upheld against a challenge that it fell outside the enumerated powers granted to Congress by the Constitution. The decision did not rule on any other aspect of the law's constitutionality, because only the particular issue of Congressional authority was properly before the Court.

Deck v. Missouri, 544 U.S. 622 (2005), was a United States Supreme Court case that dealt with the constitutionality of shackling a prisoner during the sentencing phase of a trial. In a 7–2 opinion delivered by Justice Breyer, the court held that it is against due process, a right prescribed by the 5th and 14th Amendments, to shackle a defendant in the sentencing portion of a trial unless the shackling relates to a specific defendant and certain state interests.

McCoy v. Louisiana, 584 U.S. ___ (2018), was a United States Supreme Court case in which the Court held the Sixth Amendment guarantees a defendant the right to decide that the objective of his defense is to maintain innocence at all costs, even when counsel believes that admitting guilt offers the defendant the best chance to avoid the death penalty.

Garza v. Idaho, 586 U.S. ___, 139 S. Ct. 738 (2019), was a case in which the United States Supreme Court held that the presumption of prejudice for Sixth Amendment purposes applies regardless of whether a defendant has waived the right to appeal.

Ruan v. United States, 597 U.S. ___ (2022), was a case decided by the Supreme Court of the United States.

References

  1. 1 2 Kahler v. Kansas,No. 18-6135 , 589 U.S. ___(2020).
  2. 1 2 3 Howe, Amy (March 23, 2020). "Opinion analysis: Majority upholds Kansas scheme for mentally ill defendants". SCOTUSBlog. Retrieved March 23, 2020.
  3. ↑ David, Brennan (August 14, 2011). "Kansas statute complicates case for insanity". The Columbia Tribune. Retrieved December 3, 2019.
  4. 1 2 Delling v. Idaho, 568U.S.1038 , 2-3(2012).
  5. 1 2 3 4 5 Garrett, Epps (October 6, 2019). "Does the Constitution Guarantee a Right to an Insanity Defense?". The Atlantic. The Atlantic. Retrieved November 15, 2019.
  6. ↑ Wheeler, Lydia (March 18, 2019). "Supreme Court to consider state laws abolishing the insanity defense". The Hill. Retrieved February 12, 2020.
  7. 1 2 Frye, Steve (October 7, 2019). "U.S. Supreme Court will review James Kahler insanity defense". Channel 13 WIBW. Retrieved December 3, 2019.
  8. ↑ Shastry, Sangeeta (August 24, 2011). "Kahler capable of premeditation despite depression, psychiatrist says". The Columbia Missourian. Retrieved December 3, 2019.
  9. ↑ Racino, Brad (August 30, 2011). "UPDATE: Jury sentences Kahler to death in quadruple slaying". The Columbia Missourian. Retrieved December 3, 2019.
  10. 1 2 Chilson, Morgan (February 9, 2018). "Kansas Supreme Court upholds James Kahler's murder conviction, death sentence". The Topeka Capital-Journal. Retrieved December 2, 2019.
  11. ↑ State v. Kahler, 410P.3d105 , 125( Kan. 2018).
  12. ↑ Kahler v. Kansas, 139S. Ct.1318 (2019).
  13. ↑ Vivani, Nick (March 19, 2019). "Kansas quadruple killer's SCOTUS appeal could change insanity defenses nationwide". WIBW-TV. Kansas. Retrieved November 15, 2019.
  14. ↑ Haselhorst, Sarah (October 16, 2019). "Dissecting the insanity defense through the Kahler case". Columbia Missourian. Missouri. Retrieved November 15, 2019.
  15. 1 2 3 Howe, Amy (October 7, 2019). "Argument analysis: Justices open new term with questions and concerns about insanity defense". SCOTUSBlog. Retrieved December 3, 2019.
  16. ↑ "Women, Witches, and Abortion: A Misguided Attack on Justice Alito". June 5, 2022.
  17. ↑ Wolf, Richard (March 23, 2020). "Supreme Court says states can limit scope of insanity defense". USA Today. Retrieved March 23, 2020.
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