People v. Schmidt
216 N.Y. 324 (1915)
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Rule of Law:
Under the statutory test for the insanity defense, the term 'wrong' encompasses moral wrong, not merely legal wrong. A defendant may be excused from criminal liability if, due to a mental disease or defect, they were incapable of knowing the act was morally wrong, even if they knew the act was illegal.
Facts:
- In September 1913, the dismembered body of Anna Aumuller was found in the Hudson River.
- Schmidt was arrested and repeatedly confessed that he had killed Aumuller by cutting her throat with a knife.
- At his trial, Schmidt claimed he was insane, stating he had heard the voice of God commanding him to kill the woman as a sacrifice and atonement.
- After being convicted, Schmidt changed his story, claiming that Aumuller had actually died from a criminal abortion to which he was a party.
- Schmidt admitted that he had dismembered the body to conceal the abortion and protect his confederates.
- Schmidt confessed that his entire insanity defense was a lie, fabricated in the belief that he could deceive the court, spend a short time in an asylum, and then be set free.
Procedural Posture:
- Schmidt was tried for murder in the first degree in a state trial court.
- The trial judge instructed the jury that the word 'wrong' in the insanity defense statute means 'contrary to the law of the state.'
- The jury found Schmidt guilty of murder in the first degree.
- The court condemned Schmidt to death.
- Schmidt filed a motion for a new trial on the ground of newly-discovered evidence, which was denied.
- Schmidt appealed the judgment of conviction to the New York Court of Appeals, the state's highest court.
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Issue:
Does the term 'wrong' in the statutory test for the insanity defense refer exclusively to a violation of state law, or does it also encompass a defendant's moral understanding of the act?
Opinions:
Majority - Cardozo, J.
No, the term 'wrong' in the statutory test for insanity does not refer exclusively to a violation of state law; it also encompasses moral wrong. The court holds that if a defendant is acting under an insane delusion, such as a command from God, which obscures their ability to comprehend the moral wrongness of an act, they may be excused from criminal liability even if they are aware the act is illegal. However, the court affirms Schmidt's conviction. Because Schmidt admitted in a sworn affidavit that his insanity defense was a complete fabrication to defraud the court, he has forfeited his right to challenge an erroneous jury instruction related to that fraudulent defense. A defendant is not permitted to profit from his own wrong by experimenting with one defense and, upon its failure, demanding a new trial to present another.
Analysis:
This landmark decision clarifies the M'Naghten rule by defining 'wrong' to include a moral dimension, not just a legal one. This broadens the insanity defense, creating a path for acquittal for defendants who, due to profound delusion (e.g., a divine command), lack the capacity to understand their act is morally wrong. However, the case also establishes a strong equitable principle that a defendant who perpetrates a fraud on the court by feigning a defense forfeits the right to appeal errors related to that defense. This balances the expansion of the insanity defense with a powerful deterrent against manipulating the justice system.
