State v. Crenshaw

Supreme Court of Washington, En Banc · 1983 · Criminal Law

Criminal LawInsanity DefenseEvidenceinsanityM'Naghtenright and wronglegal wrongmoral wrong

Facts

While waiting in a Washington motel for his wife to join him after he had been deported from Canada, Crenshaw became convinced she had been unfaithful. He beat her unconscious, stole a knife and stabbed her 24 times, then borrowed an ax and decapitated her. He then cleaned the motel room, concealed the body in a remote area, fled, and later confessed after telling hitchhikers about the crime. At trial he asserted insanity, claiming adherence to the Moscovite faith and prior mental problems, and he also challenged the admission of five photographs of the victim.

Issue

Whether the trial court reversibly erred by instructing the jury that in the M'Naghten insanity test 'right and wrong' means acting contrary to law, and whether the trial court abused its discretion by admitting five photographs of the decapitated victim. Also, if the insanity instruction was erroneous, whether any error was harmless.

Rule

Under Washington's statutory M'Naghten test, insanity must be established by a preponderance of the evidence by showing that, as a result of mental disease or defect, the defendant was unable to perceive the nature and quality of the act or unable to tell right from wrong with reference to the particular act charged. In this case, an instruction defining wrong in terms of legal wrong was not reversible error because M'Naghten supports that formulation on these facts, legal and moral wrong were synonymous here, and any error was harmless where the defendant failed to prove the required mental disease-or-defect causal connection and failed to prove legal insanity by a preponderance of the evidence. Prospectively, as a general rule, no definition of wrong should accompany an insanity instruction, and any instruction differing from RCW 9A.12.010 is improper. Gruesome but accurate photographs are admissible if their probative value outweighs their prejudicial effect, subject to the trial court's discretion.

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In a Washington homicide trial in Spokane, Owen Mercer pleads not guilty and not guilty by reason of insanity. Over defense objection, the judge instructs the jury using the statutory insanity language and adds, "right and wrong refers to whether the defendant knew the act was contrary to law," even though the evidence shows Owen immediately fled, discarded the weapon, and told a friend he hid because he did not want police to find him.

If Owen is convicted and appeals only the added definition of "wrong," what is the strongest basis for affirming?

Explanation. Under the majority opinion, the added legal-wrong definition was not reversible on the facts before it because M'Naghten supported that formulation where the defendant's conduct showed he knew the act was contrary to law. Concealment and flight are strong evidence of such knowledge. Although the court announced prospectively that no definition of wrong should generally accompany the instruction, it did not hold that every such instruction requires reversal.