Clark v. Arizona

Supreme Court of the United States
548 U. S. ____ (2006) (2006)

ELI5:

Rule of Law:

A state does not violate due process by either (1) defining its insanity test based solely on a defendant's capacity to determine that a criminal act was wrong, or (2) restricting evidence of mental illness and incapacity to the insanity defense, thus preventing its use to directly negate the mens rea element of a crime.

Facts:

Eric Clark, a 17-year-old with paranoid schizophrenia, suffered from delusions that government agents in his town were disguised as 'aliens' and were trying to kill him.
In the weeks preceding the incident, Clark had told acquaintances that he wanted to shoot police officers.
On June 21, 2000, Clark was circling a residential block in his truck while playing loud music.
Police Officer Jeffrey Moritz, in full uniform and driving a marked patrol car, responded to complaints about the noise.
Officer Moritz activated his emergency lights and siren, and Clark pulled his truck over.
After exiting his patrol car, Officer Moritz instructed Clark to remain in his vehicle.
Less than a minute later, Clark shot Officer Moritz, who died shortly thereafter.
Clark fled the scene on foot but was arrested later that day with gunpowder residue on his hands; the gun used in the shooting was found hidden nearby.

Procedural Posture:

Eric Clark was charged with first-degree murder in an Arizona state trial court.
After initially being found incompetent to stand trial, Clark was later deemed competent.
Clark waived his right to a jury and underwent a bench trial.
The trial court, applying the rule from State v. Mott, held that evidence of Clark's mental illness could be considered for his insanity defense but not to negate the mens rea element of the crime.
The trial judge found Clark guilty of first-degree murder, concluding he had failed to prove insanity by clear and convincing evidence.
Clark's motion to vacate the judgment on due process grounds was denied by the trial court.
Clark, as appellant, appealed to the Court of Appeals of Arizona, which affirmed his conviction, upholding the constitutionality of Arizona's insanity test and the Mott rule.
The Supreme Court of Arizona denied Clark's petition for review.
The U.S. Supreme Court granted certiorari to review the case.

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Issue:

Does a state violate due process by (1) defining its insanity test solely on a defendant's capacity to know that a criminal act was wrong, and (2) restricting evidence of mental illness to the insanity defense, thereby preventing it from being used to negate the mens rea element of the charged crime?

Opinions:

Majority - Justice Souter

No. A state does not violate due process by adopting Arizona's insanity standard or its rule restricting the use of mental illness evidence. First, due process does not mandate a single formulation for the insanity defense, and history shows a wide variety of standards have been accepted. Arizona's test, which focuses on moral incapacity (knowing right from wrong), still permits the introduction of evidence of cognitive incapacity (not knowing the nature of one's act), as cognitive incapacity is a sufficient condition to prove moral incapacity. Second, a state may channel complex mental-disease and capacity evidence to the insanity issue to avoid juror confusion and to preserve the integrity of its chosen insanity defense, which places the burden of persuasion on the defendant. Arizona's rule is a constitutional means of preventing defendants from making an end-run around the insanity defense's stricter proof requirements by creating a lesser, 'diminished capacity' defense to negate mens rea.

Concurring-in-part-and-dissenting-in-part - Justice Breyer

No, but the case should be remanded. The Constitution permits a state to distinguish between fact-based evidence of a defendant's state of mind and expert opinion evidence about mental disease or capacity, and to channel the latter two categories to the insanity defense. However, this distinction can be unclear, and it is uncertain whether the Arizona courts applied it with sufficient precision. Therefore, the case should be remanded for the state courts to determine if their law is consistent with this framework and was properly applied here, rather than affirming the conviction outright.

Dissenting - Justice Kennedy

Yes. Arizona's rules violate due process by preventing a defendant from introducing critical and reliable evidence showing he did not have the required criminal intent or knowledge. The Constitution guarantees a criminal defendant a meaningful opportunity to present a complete defense, which includes challenging the prosecution's proof on an element of the crime. The majority's distinction between observation, mental-disease, and capacity evidence is unworkable and was not the basis of the state court's decision, which broadly excluded all mental illness evidence from the mens rea determination. Funneling this evidence to the insanity defense is not an adequate substitute because it unconstitutionally shifts the burden of proof; the state must prove mens rea beyond a reasonable doubt, whereas the defendant must prove insanity by clear and convincing evidence.

Analysis:

This decision reaffirms the substantial latitude states have in defining criminal defenses and evidentiary rules. By upholding Arizona's narrow insanity test and its restriction on using mental health evidence for mens rea, the Court resisted constitutionalizing any single standard of criminal responsibility. The majority's novel tripartite evidentiary framework ('observation,' 'mental-disease,' and 'capacity' evidence) provides a new lens for analyzing due process challenges to such rules, potentially encouraging states to be more specific in their evidentiary exclusions. The ruling effectively bolsters states' ability to maintain a strict insanity defense and prevent the emergence of a de facto 'diminished capacity' defense, which could complicate prosecutions and alter burdens of proof.

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