Restriction of Insanity Defense Affirmed
Friday, June 30, 2006
States can significantly restrict the insanity defense and still give mentally troubled defendants a fair trial, the Supreme Court ruled yesterday.
Upholding an Arizona law under which a judge found a paranoid schizophrenic teenager guilty of killing a police officer, the court ruled 6 to 3 that the state's more restrictive insanity defense law did not deny the young man his due process.
Eric Clark was 17 when he shot and killed a police officer in Flagstaff. His lawyers argued that the state's 1993 insanity defense law made it virtually impossible to prove a plea of guilty but insane, and also said the judge had unfairly limited the testimony allowed about Clark's underlying illness.
Writing for the majority, Justice David Souter said that Arizona has the right to define the insanity defense as long as it meets certain standards, which he said the current law does.
Souter also wrote that judges do not have to allow testimony from mental health experts about the characteristics of a mental illness because there is considerable disagreement within the profession, and experts often disagree in court testimony.
The restrictions on testimony are acceptable, Souter wrote, because of the "controversial character of some categories of mental disease, in the potential of mental-disease evidence to mislead, and in the danger of according greater certainty to capacity evidence than experts claim for it."
Attorneys for Clark -- who did not contest the shooting -- presented evidence that he was a paranoid schizophrenic who believed Flagstaff was populated by "aliens" trying to kill him. Prosecutors acknowledged Clark's illness but argued that the schizophrenia did not keep him from understanding right from wrong at the time of the shooting.
Under Arizona's law, defendants may be found "guilty except insane'' only if they prove they were so mentally ill that they did not know what they did was wrong. Before 1993, Arizona also allowed defendants to be found guilty but insane if they were found to be without the mental capacity to know what they were doing.
Clark's case was the first direct constitutional challenge to insanity defense laws to be heard since states began to restrict them after John Hinckley's acquittal by reason of insanity in the 1981 shooting of President Ronald Reagan. Nine other states similarly restricted the insanity defense, and yesterday's ruling gives them additional support.
Justice Anthony M. Kennedy wrote in dissent that restricting expert testimony keeps a judge or jurors from receiving information they need to make sense of a defendant's claims of mental illness.
"While defining mental illness is a difficult matter, the state seems to exclude the evidence one would think most reliable by allowing unexplained and uncategorized tendencies to be introduced while excluding relatively well-understood psychiatric testimony regarding well-documented mental illnesses," he wrote.
In 2000, Clark killed officer Jeffrey Moritz, who was responding to complaints that a pickup truck playing loud rap music was circling a residential block. The officer was in uniform and was driving a patrol car when he stopped Clark, who shot him and fled.
Clark was found to be incompetent in 2001 and was committed to a state hospital. Two years later, the same trial court found that his competence had been restored and ordered him to trial.
At the trial, Clark was sentenced to life in prison, without possibility of parole for 25 years.