State v. Crenshaw
98 Wash.2d 789, 659 P.2d 488 (1983)
Crenshaw was on vacation with
his wife and decided she'd be unfaithful. So he beat her to death and
chopped her up with an axe. Then he cleaned the blood out of the hotel
room, and enlisted some hitchhikers to help him dispose the body. They
turned him into the police instead.
The police arrested Crenshaw
and charged him with first-degree murder.
Crenshaw confessed to the
crime, but pled not guilty by reason of insanity.
Crenshaw had a history of
mental problems and had been hospitalized in the past.
Crenshaw argued that he was
a member of the muscovite religion which requires death as a penalty for
adultery.
The Trial Court found Crenshaw
guilty of first-degree murder. He
appealed.
The Trial Court rejected the
insanity defense because they felt
that Crenshaw knew right from wrong when he killed his wife.
The jury had been given an
instruction that said, "what is meant by 'right and wrong' refers
to knowledge of a person at the time of committing the act that he was
acting contrary to the law."
Crenshaw argued that this
was the wrong instruction. Instead of defining 'right and wrong' as a legal right, is should be defined as a moral right.
Crenshaw argued that his
religion had told him that killing his wife was morally right,
therefore he didn't know right from wrong.
The Washington Supreme Court
upheld the conviction.
The Washington Supreme Court
found that Crenshaw knew his acts were morally wrong from society's
viewpoint and also knew they were illegal.
"His personal belief
that it was his duty to kill his wife does not exculpate him from legal
responsibility for his acts."
The Court noted that
Crenshaw attempted to cover up the crime, which shows that he knew it was
legally wrong. Crenshaw also admitted that killing your wife didn't
comport with society's standards, which shows that he knew the act was
morally wrong.
Courts around the US are
currently split as to whether the insanity defense requires a person to know that their actions are legally
wrong (aka illegal under US law), or morally wrong (aka evil).
A number of jurisdictions
leave it up to the jury to decide.