Friday, November 15, 2013

Clark v. Arizona case brief

Clark v. Arizona case brief summary
 126 S.Ct. 2709 (2006)

A trial court ruled that defendant could not rely on evidence bearing on insanity to dispute the mens rea required for first-degree murder. The Court of Appeals of Arizona affirmed defendant's conviction. Certiorari was granted to decide whether due process prohibited Arizona from narrowing its insanity test or from excluding evidence of mental illness and incapacity due to mental illness to rebut evidence of the requisite criminal intent.

Defendant, a driver, shot and killed a police officer conducting a traffic stop. Initially defendant was found incompetent to stand trial and was committed to a state hospital for treatment, but two years later the same trial court found his competence restored and ordered him to be tried. At trial, defendant did not contest the shooting and death, but relied on his undisputed paranoid schizophrenia at the time of the incident in denying that he had the specific intent to shoot a law enforcement officer or knowledge that he was doing so, as required by Ariz. Rev. Stat. § 13-1105(A)(3). Defendant challenged a 1993 amendment to Arizona's insanity rule, Ariz. Rev. Stat. § 13-502(A), excising the express reference to the cognitive incapacity element of the M'Naghten test.

  • The Court held that history showed no deference to M'Naghten that could elevate its formula to the level of fundamental principle, so as to limit the traditional recognition of a State's capacity to define crimes and defenses. 
  • Because allowing mental-disease evidence on mens rea could easily mislead, it was not unreasonable to confine consideration of that kind of evidence to the insanity defense.
See M'Naghten Rule for Criminal Insanity.

The judgment of the Court of Appeals of Arizona was affirmed.

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