State v. Crenshaw

The Supreme Court of Washington, En Banc
98 Wash. 2d 789, 659 P.2d 488 (1983)

ELI5:

Rule of Law:

Under the M'Naghten test for insanity, a defendant's personal moral code or religious beliefs cannot excuse a criminal act if the defendant knew the act was both legally wrong and contrary to society's moral standards. For heinous crimes like murder, legal wrong and societal moral wrong are considered synonymous.

Facts:

While on their honeymoon in Canada, Rodney Crenshaw was deported following a brawl.
Crenshaw secured a motel room in Blaine, Washington, and waited for his wife, Karen Crenshaw, to join him.
When Karen arrived two days later, Crenshaw immediately suspected she had been unfaithful.
Without mentioning his suspicions, Crenshaw beat his wife unconscious in the motel room.
He then stole a knife from a nearby store, returned, and stabbed her 24 times.
After the stabbing, Crenshaw borrowed an ax from a farm where he had worked, returned to the motel, and decapitated his wife.
Crenshaw testified that he followed the 'Moscovite' religious faith, which he claimed made it improper for him not to kill his wife for committing adultery.
Crenshaw had a history of mental health problems and prior hospitalizations.

Procedural Posture:

Rodney Crenshaw was charged with first degree murder in a Washington state trial court.
At trial, Crenshaw entered pleas of not guilty and not guilty by reason of insanity.
The jury rejected the insanity defense and convicted Crenshaw of first degree murder.
Crenshaw, as appellant, appealed the conviction to the Washington Court of Appeals, an intermediate appellate court.
The Court of Appeals affirmed the trial court's judgment and conviction.
Crenshaw, as petitioner, then sought review from the Supreme Court of Washington, the state's highest court.

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Issue:

Does a jury instruction for the M'Naghten insanity defense, which defines the 'right from wrong' standard as knowledge that an act is contrary to the law, constitute reversible error?

Opinions:

Majority - Brachtenbach, J.

No, the jury instruction defining 'wrong' as legally wrong does not constitute reversible error. The court held that this definition is permissible for several reasons: it is supported by the original M'Naghten case, for a crime such as murder societal 'moral wrong' is synonymous with 'legal wrong,' and any potential error was harmless. The court reasoned that the insanity defense is not available to those who act on a personal moral code that is at odds with the law; the standard is societal morality, not individual belief. Crenshaw's 'Moscovite' beliefs were not a deific decree but a personal religious tenet, which does not absolve him of responsibility. Furthermore, his calculated actions to conceal the crime—cleaning the room, hiding the body parts, and disposing of the car—demonstrated his knowledge that the act was legally wrong. The court also found any error to be harmless because overwhelming evidence, including expert testimony, supported the jury's finding that Crenshaw was legally sane.

Dissenting - Dore, J.

Yes, the jury instruction constituted prejudicial error that requires a new trial. The dissent argued that the terms 'right' and 'wrong' in the insanity statute refer to moral wrong, not merely legal wrong. While legal and moral wrong can be synonymous, this is a factual question for the jury to decide, not a matter of law for the court to dictate through an instruction. By limiting the definition to legal wrong, the court imposed a mandatory inference of sanity if the defendant knew his act was illegal, thereby usurping the jury's function. The dissent contended that the majority's own acknowledgment of a 'deific decree' exception proves that legal and moral wrong are not always identical, and Crenshaw's case presented a similar conflict that the jury should have been allowed to consider under a proper moral wrong instruction.

Analysis:

This case significantly clarifies the 'right from wrong' prong of the M'Naghten insanity defense in Washington. It establishes that for serious crimes where societal morality and the law are clearly aligned, a court may define 'wrong' as 'legally wrong' without committing reversible error. However, the court's prospective holding that, as a general rule, 'no definition of wrong should accompany an insanity defense instruction' creates a new standard for future cases. This suggests a preference for allowing the jury to determine the meaning of 'wrong' based on the arguments of counsel, thereby limiting this specific holding to its facts and steering future trials toward a less defined, more flexible standard.

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