Parsons v. State
81 Ala. 577 (1886)
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Rule of Law:
A defendant is not criminally responsible if, as a result of a mental disease, they either (1) were unable to distinguish right from wrong concerning the particular act, or (2) knew the difference between right and wrong but lost the power to choose between them, making their free agency destroyed, so long as the criminal act was solely the product of the mental disease.
Facts:
- Nancy J. Parsons was the wife of the deceased, Bennett Parsons; the other defendant was their daughter.
- Nancy Parsons held a belief that her husband possessed supernatural powers which he could use to afflict her with disease and take her life.
- As a result of this belief, Parsons was in poor health for a long period and believed she was in great danger of losing her life.
- The evidence at trial suggested Parsons was a 'lunatic' subject to insane delusions and that the killing was the product of these delusions.
- Parsons' daughter, who was alleged to be an 'idiot', shot and killed Bennett Parsons with her mother's assistance.
Procedural Posture:
- Nancy J. Parsons and her daughter were charged with the murder of Bennett Parsons in the trial court.
- The defendants entered a plea of insanity.
- The trial court instructed the jury according to the established M'Naghten 'right and wrong' test for insanity.
- A jury convicted the defendants of murder.
- The defendants appealed their convictions to the Supreme Court of Alabama.
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Issue:
Does the insanity defense in a criminal case require only a showing that the defendant did not know right from wrong, or can it also be established by showing that a mental disease destroyed the defendant's power to choose between right and wrong and to avoid the criminal act, even if they knew it was wrong?
Opinions:
Majority - Somerville, J.
No, the traditional 'right and wrong' test is not the sole standard for criminal responsibility in cases of insanity. A defendant may also be deemed not responsible if, due to a mental disease, they lost the power to choose between right and wrong, thereby destroying their free agency, and the crime was solely the product of such disease. The court reasons that the M'Naghten rule, which focuses exclusively on cognitive capacity (knowing right from wrong), has not kept pace with modern medical science. Psychological medicine recognizes that a person's volitional capacity (the power to choose or self-control) can be destroyed by a mental disease, even if their cognitive understanding remains intact. The court concludes that whether such a state of mind exists is a question of fact for the jury, not a question of law to be dictated by an outdated judicial rule. This new standard harmonizes the law with scientific understanding by recognizing that criminal intent requires both the capacity for intellectual discrimination and freedom of will.
Dissenting - Stone, C. J.
Yes, the court should adhere more closely to the established tests for insanity and be cautious about adopting psychological theories that could excuse depraved behavior. The majority's new rule, by introducing the concept of an overpowering will, dangerously approaches the discredited defense of 'moral insanity.' This could create a loophole for criminals who act on passion or depravity, rather than a true disease of the mind. The phrases 'irresistible impulse' and 'subversion of the will' are inaccurate and misleading. The dissent questions whether the defendant's delusion about supernatural powers constitutes a genuine mental disease or is merely a common superstition, citing the historical belief in witchcraft. Adopting the majority's view risks disarming retributive justice and blurring the line between the criminally irresponsible and the recklessly depraved.
Analysis:
This landmark decision dramatically altered the insanity defense in Alabama by rejecting the exclusive use of the rigid M'Naghten 'right and wrong' test. The court established the 'Parsons Test,' which incorporates a volitional or 'irresistible impulse' component alongside the traditional cognitive test. This ruling represents a significant shift in American jurisprudence toward recognizing the complexities of mental illness as understood by modern psychology and medicine. It empowers juries to consider evidence of a defendant's loss of self-control due to mental disease, setting a precedent that influenced other jurisdictions to adopt more nuanced and medically informed standards for criminal responsibility.
