State v. Corley
1972 Ariz. LEXIS 292, 108 Ariz. 240, 495 P.2d 470 (1972)
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Rule of Law:
Under the M'Naghten test for criminal insanity, the term 'wrong' is defined by generally accepted moral standards of the community and the law, not by the defendant's personal and subjective moral beliefs.
Facts:
- Dr. Sterling C. Corley was involved in a property dispute with James Stahlman.
- On June 24, 1969, Corley purchased a full box of .38 caliber ammunition.
- Later that day, Corley went to Stahlman's office and angrily confronted him, stating, 'God damn it, Jim you took a hundred feet of my property.'
- Corley insisted that Stahlman accompany him to the property in question, and Stahlman complied.
- Stahlman was last seen leaving his office with Corley.
- On June 25, 1969, Stahlman's body was found on the shore of the Colorado River.
- In the early morning of June 25, an officer in California encountered Corley and observed a 'large red stain' and a '2 inch revolver' in the front seat of the truck he was driving.
Procedural Posture:
- Dr. Sterling C. Corley was formally charged with first-degree murder in an Arizona trial court.
- Corley pled guilty to second-degree murder and raised the issue of insanity.
- A jury trial was held solely on the issue of insanity, which resulted in a hung jury and a mistrial.
- Following a state Supreme Court decision invalidating that type of trial, the case was set for a new, single trial.
- Corley was tried on an amended charge of second-degree murder, to which he pled not guilty and not guilty by reason of insanity.
- The jury returned a verdict of guilty of second-degree murder.
- Corley appealed his conviction to the Supreme Court of Arizona.
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Issue:
Under the M'Naghten test for criminal insanity, does the term 'wrong' refer to wrongfulness under generally accepted societal standards of morality, rather than the defendant's personal moral code?
Opinions:
Majority - Lockwood, Justice
Yes. The term 'wrong' in the M'Naghten test for criminal insanity refers to an act being wrong according to generally accepted moral standards of the community, not the defendant’s own individual moral standards. The court reasoned that adopting a subjective standard based on a defendant's personal beliefs would dangerously approach exonerating individuals for their private moral codes, irrespective of society's determination of their capacity to conform to the law. The court found no authority to support the defendant's position. Furthermore, the court upheld a jury instruction stating that knowledge that an act is forbidden by law permits an inference of knowledge that it is also wrong according to community moral standards, citing Justice Cardozo's opinion in People v. Schmidt.
Analysis:
This decision solidifies Arizona's interpretation of the 'wrongfulness' prong of the M'Naghten insanity defense, explicitly rejecting a subjective standard. By defining 'wrong' according to objective societal and legal standards, the court narrows the scope of the insanity defense, making it more difficult for defendants to succeed by claiming a personal, albeit delusional, moral justification for their actions. This ruling provides clear guidance for lower courts and reinforces a more traditional, objective application of the insanity test, ensuring that the defense is reserved for those who lack a fundamental understanding of societal morality, not just those who disagree with it.
