People v. Stress

California Court of Appeal
252 Cal. Rptr. 913, 1988 Cal. App. LEXIS 1061, 205 Cal. App. 3d 1259 (1988)

ELI5:

Rule of Law:

In the context of the insanity defense, the incapacity to distinguish 'right from wrong' refers to the inability to understand that an act violates generally accepted standards of moral obligation, not merely the inability to understand that the act is legally prohibited.

Facts:

Appellant Stanley Stress held a delusional belief in a conspiracy involving professional sports leagues, the government, and the media to draft athletes for war.
Stress spent years attempting to expose this conspiracy through letters and protests but felt his message was being ignored.
Facing federal charges for threatening the President, Stress feared he would be institutionalized and lose his platform.
He determined that a drastic act was necessary to force a public forum for his views and decided to kill his wife as a 'sacrifice' or 'soldier' in his war against the government.
Stress struck his sleeping 74-year-old wife in the head with an ax, killing her.
Immediately following the act, Stress called 911 to report the killing.
During subsequent psychiatric evaluations, Stress admitted he knew killing his wife was against the law but claimed it was a necessary moral act to save future generations.
Psychiatrists confirmed Stress suffered from paranoia and delusions but retained the cognitive ability to understand the legal nature of his actions.

Procedural Posture:

The State charged Stress with murder.
The trial court initially found Stress incompetent to stand trial and committed him to a state hospital.
After being returned to court, Stress underwent a bench trial.
The trial court found Stress guilty of murder in the first degree.
In the subsequent sanity phase, the trial court found Stress was sane at the time of the commission of the crime.
Stress appealed both the judgment of conviction and the finding of sanity to the Court of Appeal.

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Issue:

Does the statutory definition of insanity, which requires a defendant to be incapable of distinguishing 'right from wrong,' apply when a defendant understands his act is legally criminal but, due to mental illness, believes it is morally justified?

Opinions:

Majority - Justice Benke

Yes, the definition of 'wrong' in the insanity defense encompasses generally accepted moral standards, not just legal criminality. The court affirmed the murder conviction but reversed the sanity finding. Regarding the murder conviction, the court rejected the appellant's argument that express malice requires 'wanton disregard' or 'antisocial motivation,' holding that a deliberate intent to kill is sufficient. The court also held that legislative amendments had removed the requirement to prove 'mature and meaningful reflection' for premeditation; therefore, the appellant's careful planning supported the first-degree murder verdict despite his delusions. However, on the issue of sanity, the court found the trial judge erred by applying a strict legal standard. The trial judge had ruled that because Stress knew the act was illegal, he was sane. The appellate court cited People v. Skinner, establishing that a defendant is insane if they cannot distinguish moral right from wrong. Since evidence suggested Stress believed his act was morally right (despite knowing it was illegal), the trial court's use of the wrong legal test was prejudicial. The case was remanded for a new sanity hearing.

Analysis:

This case is significant for two reasons. First, it cements the post-1981 legislative intent to eliminate 'diminished capacity' by confirming that 'mature and meaningful reflection' is no longer required for first-degree murder; a mentally ill defendant can still 'premeditate' in the eyes of the law if they plan the crime. Second, and most importantly, it clarifies the M'Naghten rule for insanity in California. It establishes a 'moral' component to the 'right vs. wrong' test. Even if a defendant knows an act is a crime (legal wrong), they may still be found insane if their mental illness prevents them from understanding that the act is morally wrong according to societal standards. This prevents the conviction of individuals who, like Stress, act out of a delusional moral imperative (e.g., 'God told me to,' or 'I must save the world') even while acknowledging the act is illegal.

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