State v. Worlock
117 N.J. 596, 1990 N.J. LEXIS 13, 569 A.2d 1314 (1990)
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Rule of Law:
Under New Jersey's M'Naghten insanity defense, the term 'wrong' is judged by societal standards of morality, not the defendant's personal moral code. A specific jury instruction distinguishing between legal and moral wrong is required only in exceptional cases where a defendant's delusion, such as a claimed 'command from God,' creates a conflict between the law and a distorted view of societal morality.
Facts:
- Carlyle Worlock had an unstable friendship with Guy Abrahamsen and Shawn Marchyshyn, who would sometimes ridicule and abuse him.
- After a night of partying at Worlock's expense, Abrahamsen took Worlock's pants under the pretense of washing them, but actually stole his wallet.
- The wallet contained approximately $130 and an embarrassing photograph of Worlock that he feared Abrahamsen would use to 'destroy' him.
- Feeling betrayed, Worlock retrieved a semi-automatic rifle he had previously hidden in a wooded area.
- His suspicion that his money had been stolen was confirmed when he saw Abrahamsen and Marchyshyn exit a taxi.
- Worlock waited in ambush and, when the two men approached, he moved within fifteen feet and fired twelve rounds.
- He aimed at Abrahamsen but first struck and killed Marchyshyn.
- Worlock then fired a second burst of bullets, hitting and killing Abrahamsen as he tried to enter an apartment.
Procedural Posture:
- An Ocean County Grand Jury indicted Carlyle Worlock for the capital murder of Guy Abrahamsen and Shawn Marchyshyn and for unlawful possession of a weapon.
- At trial in the state's court of first instance, the principal issue was Worlock's insanity defense.
- A jury found Worlock guilty of murder and the weapons charge.
- Worlock appealed his conviction to the Appellate Division, an intermediate appellate court.
- The Appellate Division affirmed the conviction.
- The Supreme Court of New Jersey, the state's highest court, granted certification to hear Worlock's appeal.
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Issue:
Does a trial court commit plain error by not specifically instructing the jury that the term 'wrong' in the statutory insanity defense encompasses moral wrong, when the defendant's justification for the crime is based on a personal moral code rather than a recognized delusion?
Opinions:
Majority - Justice Pollock
No. A trial court does not commit plain error by not giving a specific instruction on moral wrong when a defendant's insanity claim rests on a personal code of conduct. The term 'wrong' within the M'Naghten insanity defense is judged by societal standards, not the defendant's idiosyncratic beliefs. An instruction distinguishing legal and moral wrong is only necessary in the exceptional case where the defendant claims a delusion, such as a deific command, that pits a distorted view of societal morality against the law. Here, Worlock admitted he knew his actions were illegal and contrary to societal morals but believed they were justified under his personal code ('might makes right'), which does not meet the standard for an insanity defense. The court also held that the doctrine of 'transferred intent' applies even when the intended victim is also killed, meaning a defendant can be convicted of the purposeful murder of an unintended victim.
Analysis:
This decision clarifies the scope of the insanity defense in New Jersey by narrowly defining the term 'wrong' within the M'Naghten test. By holding that 'wrong' must be measured against societal standards of morality, the court prevents the defense from being expanded to include justifications based on a defendant's personal, subjective, or antisocial moral code. The ruling establishes that a specific jury instruction distinguishing legal from moral wrong is a rare necessity, reserved for cases involving specific, recognized delusions like a 'deific decree.' This reinforces the high bar for successfully asserting an insanity defense and limits its application to cases of severe cognitive impairment recognized by law, not mere philosophical disagreement with societal norms.
