O. C. Wilkinson, Jr. v. The State of Texas
423 S.W.2d 311 (1968)
Rule of Law:
In Texas, the legal test for insanity is the 'right and wrong' test, also known as the M'Naghten rule, which focuses on whether the defendant, at the time of the offense, had the cognitive capacity to know their conduct was wrong.
Facts:
- An act of robbery with a firearm was committed.
- The appellant was identified as the perpetrator of the robbery.
- At the time of the offense, the appellant had a mental condition that formed the basis for a subsequent insanity defense.
- Psychiatric examinations of the appellant were conducted on two separate occasions by two different psychiatrists.
Procedural Posture:
- The State of Texas charged the appellant with robbery with firearms.
- Appellant interposed an insanity defense at trial in the court of first instance.
- The trial court instructed the jury on the 'right and wrong' test for insanity.
- A jury found the appellant sane at the time of the offense and at the time of trial, and returned a verdict of guilty.
- The trial court entered a judgment of conviction and sentenced the appellant to twenty-five years.
- The appellant appealed the conviction to the Texas Court of Criminal Appeals, which is the state's highest court for criminal matters.
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Issue:
Does the use of the 'right and wrong' test, also known as the M'Naghten rule, in a jury instruction on the defense of insanity constitute a proper application of Texas law?
Opinions:
Majority - Dice, Judge
Yes, the use of the 'right and wrong' test is a proper application of Texas law. The court reaffirms that the M'Naghten 'right and wrong' test is the established and correct legal standard for determining insanity in the state. While acknowledging that other jurisdictions have adopted different tests, the court explicitly adheres to its own precedent, citing Ross v. State, Freeman v. State, and Bush v. State. The court also rejects the appellant's other grounds for error, finding that the psychiatric examinations were adequate, the admission of a certified copy of a prior sanity judgment was proper, trying the appellant in jail clothes without an objection did not constitute reversible error, and the trial court did not abuse its discretion by refusing to reopen the case for further testimony.
Analysis:
This opinion strongly reaffirms Texas's commitment to the traditional M'Naghten rule for legal insanity, resisting the trend in other jurisdictions toward broader tests that might consider volitional incapacity. By explicitly adhering to its precedent, the court signals a high degree of judicial conservatism and respect for stare decisis in this area of criminal defense. The decision solidifies a narrow, cognitive-based standard for insanity in Texas, making it difficult for defendants to succeed with this defense unless they can prove a complete lack of understanding that their actions were wrong. This case serves as a clear statement that challenges to the fundamental test for insanity will face significant resistance in Texas courts.
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