People v. Skinner
39 Cal. 3d 765, 704 P.2d 752, 217 Cal. Rptr. 685 (1985)
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Rule of Law:
California's statutory insanity defense, Penal Code § 25(b), restores the traditional M'Naghten test, under which a defendant is legally insane if, due to mental disease or defect, they were incapable of either knowing the nature and quality of their act OR of distinguishing right from wrong. The 'right from wrong' prong refers to both moral and legal wrong.
Facts:
- The defendant, Skinner, was a patient at Camarillo State Hospital.
- Skinner suffered from paranoid schizophrenia or a similar schizoaffective illness.
- As a result of his illness, Skinner had a delusion that the marriage vow 'till death do us part' gave him a God-given right to kill his wife for being unfaithful.
- He believed this act was morally and criminally justified because it was sanctified by God.
- While on a day pass from the hospital, Skinner strangled and killed his wife.
- At the time of the killing, Skinner understood he was strangling a person and that this act would cause death.
- Due to his delusion, however, Skinner did not believe his act was wrong.
Procedural Posture:
- The defendant, Skinner, was charged with second-degree murder in a California trial court.
- Skinner entered pleas of nolo contendere and not guilty by reason of insanity.
- The case was tried before a judge after a jury was waived.
- The trial judge found that Skinner knew the nature and quality of his act but could not distinguish right from wrong.
- Interpreting Penal Code § 25(b) as requiring a defendant to prove both prongs of the test, the trial judge found Skinner legally sane.
- The trial court entered a judgment of conviction for second-degree murder.
- Skinner appealed the judgment of conviction to the Supreme Court of California.
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Issue:
Does California Penal Code § 25(b), which defines insanity as being incapable of knowing the nature of one's act 'and' of distinguishing right from wrong, require a defendant to prove both elements conjunctively, and does the 'right from wrong' element refer exclusively to legal wrong?
Opinions:
Majority - Grodin, J.
No. California Penal Code § 25(b) was intended to restore the traditional, disjunctive M'Naghten test for insanity, and the 'right from wrong' prong encompasses an inability to distinguish moral wrong, not just legal wrong. The court determined that the electorate's intent in passing Proposition 8 was to abrogate the ALI test from People v. Drew and reinstate the version of the M'Naghten test that had existed in California for over a century. A literal reading of the statute's use of 'and' would create a new, radically strict test, essentially a 'wild beast' test, which there is no evidence the voters intended. Such a drastic change would also raise serious due process questions about punishing individuals who lack the essential element of criminal intent (mens rea). Therefore, the court construes the conjunctive 'and' as a drafting error that should be read as the disjunctive 'or'. Furthermore, the court held that California's historical application of M'Naghten, as confirmed in cases like People v. Wolff, defines 'wrong' to include moral wrong. A defendant who acts under an insane delusion that God has ordained their act cannot be said to 'know' the act is wrong, even if they are aware it is illegal.
Dissenting - Bird, C. J.
Yes. The court should apply the statute as written because the language is unambiguous. The dissent argues that Penal Code § 25, subdivision (b) plainly requires the accused to demonstrate that they were incapable of knowing the nature of their act 'and' of distinguishing right from wrong. The court's role is not to rewrite a statute to correct what it perceives as an unwise choice made by the electorate. Since the language is clear and there is no evidence that the voters intended 'and' to mean 'or,' the court is bound by the plain meaning of the text. Because the appellant failed to establish his insanity under this conjunctive test, the judgment should be affirmed.
Concurring - Mosk, J.
No. The majority's analysis is correct, and some historical context demonstrates why. The concurrence agrees with the majority's conclusion, noting that the use of 'and' instead of 'or' was almost certainly a drafting error that would have been discovered and corrected through the traditional legislative process. This error highlights a key flaw in adopting complex legal rules through voter initiatives, which lack mechanisms for revision or clarification. Justice Mosk also reiterates his belief that Proposition 8 was unconstitutional for violating the single-subject rule, and this case represents one of the many 'uncertainties and incongruities' that resulted from the court's failure to invalidate it. Given that Proposition 8 is law, the majority's pragmatic interpretation is the most reasonable way to inject meaning into its 'clumsy' language.
Analysis:
This decision is significant for preserving the viability of the insanity defense in California after the passage of Proposition 8. By interpreting the statute's 'and' as 'or,' the court prevented a drastic narrowing of the defense that would have made it nearly impossible for most mentally ill defendants to meet the standard. This judicial construction avoided a return to the archaic 'wild beast' test and side-stepped potential constitutional due process challenges. Furthermore, the court's affirmation that 'wrong' includes moral wrong maintains a crucial aspect of the defense for defendants who, due to severe delusions, believe their actions are morally justified even if they understand them to be illegal.
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