Clark v. Arizona

Clark v. Arizona

Argued April 19, 2006
Decided June 29, 2006
Full case name Eric Michael Clark v. State of Arizona
Docket nos. 05-5966
Citations

548 U.S. 735 (more)

126 S.Ct. 2709; 2006 U.S. LEXIS 5184; 2006 WL 1764372
Prior history Defendant convicted, Coconino County Superior Court, Sept. 3, 2003; affirmed, Ariz. Ct. App., Jan. 25, 2005; review denied, Ariz., May 25, 2005; cert. granted, 126 S. Ct. 797 (2005)
Holding
Due process does not prohibit Arizona's use of an insanity test stated solely in terms of the capacity to tell whether an act charged as a crime was right or wrong. The state could also constitutionally limit a defendant's evidence of mental defect to only what is relevant to that insanity test, even when mens rea is an element of the charged crime. Arizona Court of Appeals affirmed.
Court membership
Chief Justice
John G. Roberts
Case opinions
Majority Souter, joined by Roberts, Scalia, Thomas, Alito; Breyer except parts III-B, III-C, and ultimate disposition
Concur/dissent Breyer
Dissent Kennedy, joined by Stevens, Ginsburg
Laws applied
U.S. Const. amend. XIV; Ariz. Rev. Stat. § 13-502(A)

Clark v. Arizona, 548 U.S. 735 (2006), is a United States Supreme Court case in which the Court upheld the constitutionality of the insanity defense used by the State of Arizona. The ruling affirmed the murder conviction of a man with paranoid schizophrenia, for the killing of a police officer. The man had argued that his inability to understand the nature of his acts at the time they were committed should be a sufficient basis for showing he lacked the requisite mental state required as an element of the charged crime. The Court upheld Arizona's restriction of admissible mental health evidence only to the issue of insanity. Arizona does not allow mental health evidence to show that the defendant did not possess the required mental intent level necessary to satisfy an element of the crime. The evidence is only admissible if used to show that the defendant was insane at the time of the crime's commission. In this case, the defendant knew right from wrong so he could not qualify under Arizona's insanity defense.

Background

In the court case, Clark v. Arizona the constitutionality of an insanity defense was questioned. Also, whether or not a defendant has a Fourteenth Amendment due process right, unrelated to his/her insanity plea, in order to present the correct evidence regarding his mental state to counter the prosecution’s evidence of criminal intent.[1] In the case, Eric Clark shot and killed a police officer at a traffic stop because he believed his town in Arizona had been taken over by aliens. Clark, was a diagnosed schizophrenic and pleaded on behalf of the insanity defense in hopes of using his mental disorder as an excuse for the crime he committed. The court did not believe Clark proving his insanity defense was a justifiable defense and was sentenced to 25 years in prison. Throughout the court case, Clark presented an elaborate testimony describing his odd behavior a year prior to the incident. Among many other things, Clark believed “aliens”, some being government people, were trying to hurt and kill him and the only way to stop them was through death. A psychiatrist testified that Clark was suffering from paranoid schizophrenia, a type of schizophrenia that a patient has delusions that a person is against them and/or their family,[2] at the time of the shooting and was incapable of deciding right from wrong at the time of the shooting, thus being insane. Before being tried again Clark was committed to a mental institution for two years, after those two years Clark’s belief in aliens was still present but he no longer believed they were out to get him but they had another mission.[3]

Supreme Court Decision

In a 5-4 decision, in favor of Arizona, the supreme court decided that the Arizona court could limit the amount of evidence used to plea a person’s sanity for a defendant’s insanity defense.[1] Justice Souter believes that having a defendant prove his insanity in order to justify they were unable to clearly think while committing the crime would disprove his claim for insanity because they were able to think clearly to prove they were insane.[1] The court cited the Supreme Court’s decision in State v. Mott, which refused to allow a psychiatric testimony to invalidate a criminal’s intent and to uphold that Arizona does not allow evidence of a mental illness to neutralize the mens rea of a crime.[4] Mens Rea is an element of criminal responsibility regarding whether or not there was intention or knowledge of wrongdoing while a crime was being committed.[5] The court also determined that due process does not require a State to use both areas of the M'Naughten insanity test. Rather, a State may adopt an insanity test that focuses solely on moral incapacity.[6]

Dissents from the Court

Judges Ginsburg, Kennedy, and Stevens disagreed with the majority ruling of the court. Justice Breyer was in partial concurrence and dissents he states that he agrees with the courts "basic categorization" of evidence related to insanity. Further, he acknowledges that a State may provide consideration of mental-disease "solely in conjunction with the insanity defense." However, Justice Breyer dissents from the majority's opinion and would change the case so that Arizona courts could determine whether state law is consistent.

In dissent, Justice Kennedy starts off by stating that it is not necessary for him to address Clark's due process challenge to Arizona's insanity test. Instead, he disagrees with the majority for limiting Clark's claim to evidentiary support on his insanity. Justice Kennedy also believes the Mott Rule, a rule that does not allow evidence for insanity to prove someone is not guilty,[6] in the case is unjust because it constitutes an exclusion of evidence, despite the credibility.[6]

Disagreements Regarding the Case

Everyone believed that Clark was a paranoid schizophrenic and suffering from the disease when he shot Officer Moritz.[3] There was also no disagreement of whether or not Clark actually believed there were aliens who were out to get him as he hung fishing line in his room as “booby traps”, as well as wind chimes on the doors and windows to warn him of intruders.[3] Lastly, Clark kept a bird in his car in order to warn him of different changes in air temperature which could lead to possible intruders.

There is some disagreement on the reasoning behind Clark’s action the night of the crime. For example on the day of the crime Clark was blasting music in his car, the state believes this was done in order to lure the officer to his vehicle, as he had mentioned to a friend that he wanted to shoot a cop.[3] The defense expert, Dr. Morentz dismissed this theory as he believes Clark was playing music loudly in order to “drown out” the voices in his head as most paranoid schizophrenics do.[3]

The state and defense’s opinion on whether or not Clark was actually schizophrenic began to agree again after Clark was sent to jail. Clark called the prison guards aliens and refused to eat out of fear of being poisoned by aliens.[3]

Application of Insanity Laws in the United States

Depending on the state, they will apply the insanity law by means of burden of proof. The burden of proof is either on the prosecutor, in which the prosecutor must prove that the defendant is not insane, or on the defense. If the burden of the proof is on the defense side they must prove the defendant is insane. After the application of the insanity defense began states also acquired a law in Jones v. United States that requires people released due to insanity to be held in a mental hospital for a similar time they would be in prison.[7] The courts also require that the subject in question is able to withstand a trial, if not they must be hospitalized until they are able to go to trial. Another way a case regarding mental illness is handled is the verdict being “guilty but mentally ill”, in these scenarios the person is given a sentence but is offered psychiatric treatment while incarcerated or is taken to a mental hospital, once they are believed to be capable enough they are taken to a prison to serve the remainder of their sentence.[7]

History of Insanity Laws in the United States

The insanity defense has existed since the twelfth century and is one of most controversial yet least used criminal defense strategies. It claims that a criminal defendant should not be found guilty because of the defendant’s insanity. Theory being that a person who is insane lacks the understanding of the crime they are performing or the difference between right and wrong. Initially the defense could only be used to pardon a criminal’s sentence. The concept that one’s insanity could rid them of their sentence began in the nineteenth century in Isaac Ray’s, The Medical Jurisprudence of Insanity and the decision in England called the M'Naghten case.[7]

In 1843, Daniel M'Naghten a paranoid schizophrenic was under the idea that he was being persecuted causing him to shoot and kill Edward Drummond.[7] M'Naghten was found not guilty on the grounds that he was insane at the time of his act. The public were outraged by this rulings causing standards for the insanity defense to be established, often referred to as the M'Naghten Rule.

The M'Naghten Rule states: every person is assumed to be sane and in order to establish a ground of insanity, it must be proven clearly that at the time of committing a crime, the criminal was acting due to a “defect of reason”[7] or mental illness, causing them not to understand the degree of his act.[7] Test for the M’Naghten rule include distinguishing whether or not a defendant can determine the difference between right and wrong.

One of the best known applications of the insanity defense was in the Hinckley Trial. This trial was for John W. Hinckley, a man who attempted to assassinate Ronald Reagan in 1982. He was ultimately acquitted of his charges under the insanity defense.[7] The outrage after this court decision caused four states to eliminate the insanity defense: Montana, Utah, Idaho, and Kansas.[7]

References

  1. 1 2 3 "Clark V. Arizona". oyez.com.
  2. ↑ "Paranoid Schizophrenia: Causes, Symptoms and Treatments". Medical News Today. Retrieved 2016-10-27.
  3. 1 2 3 4 5 6 Rozelle, Susan. "Clark v. Arizona".
  4. ↑ Souter, David. "Supreme Court of the United States Clark v. Arizona".
  5. ↑ "mens rea". TheFreeDictionary.com. Retrieved 2016-10-27.
  6. 1 2 3 "Yesterday's Decision in Clark v. Arizona". SCOTUSblog. 2006-06-30. Retrieved 2016-10-27.
  7. 1 2 3 4 5 6 7 8 "United States Insanity Defense Law Summary and Law Digest". lawdigest.uslegal.com. Retrieved 2016-10-27.

External links

Court documents

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