M'Naghten rule (Minnesota) · Go Syfert
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M'Naghten rule in Minnesota

20 Minnesota opinions name it 2 courts 1967–2026 1 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
State v. Odellgreen
minn · 2004 · cited in 3 Minnesota opinions naming this issue, 2006–2016
2 sentences

2016The mental-illness defense in Minnesota follows the M’Naghten rule, 3 see State v. Odell, 676 N.W.2d 646, 647 (Minn.2004), which is codified by statute: *868 No person having a mental illness or cognitive impairment so as to be incapable of understanding the proceedings or making a defense shall be tried, sentenced, or punished for any crime; but the person shall not be excused from criminal liability except upon proof that at the time of committing the alleged criminal act the person was laboring under such a defect of reason, from one of these causes, as not to know the nature of the act, or

2016The mental-illness defense in Minnesota follows the M’Naghten rule, 3 see State v. Odell, 676 N.W.2d 646, 647 (Minn.2004), which is codified by statute: *868 No person having a mental illness or cognitive impairment so as to be incapable of understanding the proceedings or making a defense shall be tried, sentenced, or punished for any crime; but the person shall not be excused from criminal liability except upon proof that at the time of committing the alleged criminal act the person was laboring under such a defect of reason, from one of these causes, as not to know the nature of the act, or

33
State v. Dhaemersgreen
minn · 1967 · cited in 3 Minnesota opinions naming this issue, 1972–2003
2 sentences

2003See, e.g., State v. Dhaemers, 276 Minn. 332, 339 , 150 N.W.2d 61, 66 (1967) ("While we agree that the M’Naghten rule should have been discarded with the horse and buggy * * *."); State v. Eubanks, 277 Minn. 257, 263-64 , 152 N.W.2d 453, 457 (1967) ("While we do not imply that the defense did not present a convincing case for the fact that the M'Naghten rule is an ancient and archaic tool for criminal responsibility * * *.”).

2003See, e.g., State v. Dhaemers, 276 Minn. 332, 339 , 150 N.W.2d 61, 66 (1967) ("While we agree that the M’Naghten rule should have been discarded with the horse and buggy * * *."); State v. Eubanks, 277 Minn. 257, 263-64 , 152 N.W.2d 453, 457 (1967) ("While we do not imply that the defense did not present a convincing case for the fact that the M'Naghten rule is an ancient and archaic tool for criminal responsibility * * *.”).

33
State v. Finngreen
minn · 1960 · cited in 5 Minnesota opinions naming this issue, 1967–2007
2 sentences

2007See State v. Finn, 257 Minn. 138, 140, 100 N.W.2d 508, 510-11 (1960) (recognizing the codification of the M’Naghten rule).

2007See State v. Finn, 257 Minn. 138, 140, 100 N.W.2d 508, 510-11 (1960) (recognizing the codification of the M’Naghten rule).

25
DeMars v. Stategreen
minn · 1984 · cited in 2 Minnesota opinions naming this issue, 2004–2009
2 sentences

2009De-Mars v. State, 352 N.W.2d 13, 16 (Minn.1984) (citing State v. Malley, 285 N.W.2d 469 , 472 n. 3 (Minn.1979)); see Minn.Stat. § 611.025 (2008).

2009De-Mars v. State, 352 N.W.2d 13, 16 (Minn.1984) (citing State v. Malley, 285 N.W.2d 469 , 472 n. 3 (Minn.1979)); see Minn.Stat. § 611.025 (2008).

22
In re Disciplinary Action Against Rojasgreen
minn · 2016 · cited in 1 Minnesota opinions naming this issue, 2026–2026
2 sentences

2026See State v. Roberts, 876 N.W.2d 863, 867 (Minn. 2016) (citing M’Naghten’s Case (1843) 8 Eng.

2026See State v. Roberts, 876 N.W.2d 863, 867 (Minn. 2016) (citing M’Naghten’s Case (1843) 8 Eng.

11
State v. McLaughlingreen
minn · 2007 · cited in 1 Minnesota opinions naming this issue, 2009–2009
2 sentences

2009See State v. McLaughlin, 725 N.W.2d 703 , 708 n. 3 (Minn.2007).

2009See State v. McLaughlin, 725 N.W.2d 703 , 708 n. 3 (Minn.2007).

11
State v. Barnesgreen
minn · 2006 · cited in 1 Minnesota opinions naming this issue, 2007–2007
1 sentence

2007See Barnes, 713 N.W.2d at 333 .

11
Bruestle v. Stategreen
minn · 2006 · cited in 1 Minnesota opinions naming this issue, 2007–2007
2 sentences

2007See Bruestle v. State, 719 N.W.2d 698, 704 (Minn.2006).

2007See Bruestle v. State, 719 N.W.2d 698, 704 (Minn.2006).

11
Davis v. Stategreen
minn · 1999 · cited in 1 Minnesota opinions naming this issue, 2004–2004
2 sentences

2004Davis v. State, 595 N.W.2d 520, 526 (Minn.1999); see also Minn.Stat. § 611.026. “[A] defendant must prove mental illness at the time of the crime by a preponderance of the evidence.” DeMars v. State, 352 N.W.2d 13, 16 (Minn.1984).

2004Davis v. State, 595 N.W.2d 520, 526 (Minn.1999); see also Minn.Stat. § 611.026. “[A] defendant must prove mental illness at the time of the crime by a preponderance of the evidence.” DeMars v. State, 352 N.W.2d 13, 16 (Minn.1984).

11
State v. Barsnessgreen
minnctapp · 1991 · cited in 1 Minnesota opinions naming this issue, 2003–2003
2 sentences

2003See State v. Barsness, 473 N.W.2d 325, 329 (Minn.App.1991) (holding that mentally retarded defendant who was found guilty of second-degree murder and manslaughter qualified for downward sentencing departure), review denied (Minn. Aug. 29, 1991).

2003See State v. Barsness, 473 N.W.2d 325, 329 (Minn.App.1991) (holding that mentally retarded defendant who was found guilty of second-degree murder and manslaughter qualified for downward sentencing departure), review denied (Minn. Aug. 29, 1991).

11
State v. Eubanksgreen
minn · 1967 · cited in 1 Minnesota opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., State v. Dhaemers, 276 Minn. 332, 339 , 150 N.W.2d 61, 66 (1967) ("While we agree that the M’Naghten rule should have been discarded with the horse and buggy * * *."); State v. Eubanks, 277 Minn. 257, 263-64 , 152 N.W.2d 453, 457 (1967) ("While we do not imply that the defense did not present a convincing case for the fact that the M'Naghten rule is an ancient and archaic tool for criminal responsibility * * *.”).

2003See, e.g., State v. Dhaemers, 276 Minn. 332, 339 , 150 N.W.2d 61, 66 (1967) ("While we agree that the M’Naghten rule should have been discarded with the horse and buggy * * *."); State v. Eubanks, 277 Minn. 257, 263-64 , 152 N.W.2d 453, 457 (1967) ("While we do not imply that the defense did not present a convincing case for the fact that the M'Naghten rule is an ancient and archaic tool for criminal responsibility * * *.”).

11
State v. Hoffmangreen
minn · 1982 · cited in 1 Minnesota opinions naming this issue, 1987–1987
2 sentences

1987Bouwman, 328 N.W.2d at 705 ; State v. Hoffman, 328 N.W.2d 709, 716 (Minn.1982). 4 .

1987Bouwman, 328 N.W.2d at 705 ; State v. Hoffman, 328 N.W.2d 709, 716 (Minn.1982). 4 .

11
State v. Lindergreen
minn · 1981 · cited in 1 Minnesota opinions naming this issue, 1987–1987
2 sentences

1987Minn. Stat. § 611.026 (1986); State v. Linder, 304 N.W.2d 902, 907 (Minn.1981).

1987Minn. Stat. § 611.026 (1986); State v. Linder, 304 N.W.2d 902, 907 (Minn.1981).

11
State v. Bouwmangreen
minn · 1982 · cited in 1 Minnesota opinions naming this issue, 1985–1985
2 sentences

1985State v. Bouwman, 328 N.W.2d 703, 705 (Minn.1982); see Daniel M’Naghten’s case, 10 Clark & Finnelly 200, 8 Eng.Rep. 718.

1985State v. Bouwman, 328 N.W.2d 703, 705 (Minn.1982); see Daniel M’Naghten’s case, 10 Clark & Finnelly 200, 8 Eng.Rep. 718.

11
State v. Whitegreen
nm · 1954 · cited in 1 Minnesota opinions naming this issue, 1972–1972
2 sentences

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
State v. Malley green
minn · 1979
2 sentences

2009De-Mars v. State, 352 N.W.2d 13, 16 (Minn.1984) (citing State v. Malley, 285 N.W.2d 469 , 472 n. 3 (Minn.1979)); see Minn.Stat. § 611.025 (2008).

2009De-Mars v. State, 352 N.W.2d 13, 16 (Minn.1984) (citing State v. Malley, 285 N.W.2d 469 , 472 n. 3 (Minn.1979)); see Minn.Stat. § 611.025 (2008).

21987–2009
State v. Rawland green
minn · 1972
2 sentences

2007Yet, in Rawland , we held that a defendant is permitted to introduce evidence regarding his vulnerability to "irresistible impulses,” and a factfinder may consider this evidence in determining whether a defendant meets the M’Naghten standard. 294 Minn, at 43-46, 199 N.W.2d at 789-90 . 9 .

2007Rowland, 294 Minn, at 31-35, 199 N.W.2d at 782-84 .

21997–2007
State v. Gut green
minn · 1868
2 sentences

1992It was adopted by this court in State v. Gut, 13 Minn. 341 ( Gil. 315 ) (1868) and today is codified as Minn.Stat. § 611.026 (1990).

1992It was adopted by this court in State v. Gut, 13 Minn. 341 ( Gil. 315 ) (1868) and today is codified as Minn.Stat. § 611.026 (1990).

21981–1992
Schleicher v. State green
minn · 2006
2 sentences

2007Schleicher v. State, 718 N.W.2d 440 , 448 n. 7 (Minn.2006); Finn, 257 Minn, at 141-42, 100 N.W.2d at 511 . 11 .

2007Schleicher v. State, 718 N.W.2d 440 , 448 n. 7 (Minn.2006); Finn, 257 Minn, at 141-42, 100 N.W.2d at 511 . 11 .

12007–2007
Penry v. Lynaugh red
scotus · 1989
2 sentences

1995He argues that even if this court concludes that he does not meet the M’Naghten test, his disturbed mental state at the time of the murders made Mm “less morally culpable than defendants who have no such excuse.” Penry v. Lynaugh, 492 U.S. 302, 322 , 109 S.Ct. 2934, 2949 , 106 L.Ed.2d 256 (1989) (holding that mental retardation was a mitigating factor to be considered by jurors in capital murder case).

1995He argues that even if this court concludes that he does not meet the M’Naghten test, his disturbed mental state at the time of the murders made Mm “less morally culpable than defendants who have no such excuse.” Penry v. Lynaugh, 492 U.S. 302, 322 , 109 S.Ct. 2934, 2949 , 106 L.Ed.2d 256 (1989) (holding that mental retardation was a mitigating factor to be considered by jurors in capital murder case).

11995–1995
Gray v. First Division of the St. Paul & Pacific R. R. green
minn · 1868
2 sentences

1972State v. Gut, 13 Minn. 315 (341) (1868).

1972State v. Gut, 13 Minn. 315 (341) (1868).

11972–1972
State v. Scott neutral
minn · 1889
2 sentences

1972For a more complete discussion of the M’Naghten rule and its adoption in Minnesota, see, State v. Scott, 41 Minn. 365 , 43 N. W. 62 (1889); State v. Finn, 257 Minn. 138 , 100 N. W. 2d 508 (1960); and comment by the Advisory Committee on Revision of the Criminal Law appearing in Proposed Minnesota Criminal Code, p. 32 (1962).

1972For a more complete discussion of the M’Naghten rule and its adoption in Minnesota, see, State v. Scott, 41 Minn. 365 , 43 N. W. 62 (1889); State v. Finn, 257 Minn. 138 , 100 N. W. 2d 508 (1960); and comment by the Advisory Committee on Revision of the Criminal Law appearing in Proposed Minnesota Criminal Code, p. 32 (1962).

11972–1972
State v. Simenson neutral
minn · 1935
2 sentences

1972See, State v. Finn, 257 Minn. 138 , 100 N. W. 2d 508 (1960); State v. Simenson, 195 Minn. 258 , 262 N. W. 638 (1935); State v. Scott, 41 Minn. 365 , 43 N. W. 62 (1889).

1972See, State v. Finn, 257 Minn. 138 , 100 N. W. 2d 508 (1960); State v. Simenson, 195 Minn. 258 , 262 N. W. 638 (1935); State v. Scott, 41 Minn. 365 , 43 N. W. 62 (1889).

11972–1972
Leland v. Oregon green
scotus · 1952
2 sentences

1972In its last expression on the subject in 1952, the United States Supreme Court in Leland v. Oregon, 343 U. S. 790 , 72 S. Ct. 1002 , 96 L. ed. 1302, with Justices Frankfurter and Black dissenting, refused to hold that the Oregon version of the M’Naghten rule violated the Fourteenth Amendment to the United States Constitution.

1972In its last expression on the subject in 1952, the United States Supreme Court in Leland v. Oregon, 343 U. S. 790 , 72 S. Ct. 1002 , 96 L. ed. 1302, with Justices Frankfurter and Black dissenting, refused to hold that the Oregon version of the M’Naghten rule violated the Fourteenth Amendment to the United States Constitution.

11972–1972
People v. Martin green
mich · 1971
2 sentences

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

11972–1972
State v. Shoffner green
wis · 1966
2 sentences

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

11972–1972
State v. White green
idaho · 1969
2 sentences

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

1972See, for example, State v. White, 58 N. Mex. 324, 330, 270 P. 2d 727, 730 (1954); State v. Shoffner, 31 Wis. 2d 412 , 143 N. W. 2d 458 (1966); State v. White, 93 Idaho 153 , 456 P. 2d 797 (1969); People v. Martin, 386 Mich. 407 , 192 N. W. 2d 215 (1971); Pope v. United States, supra. From our review of the authorities, we have a strong impression that all courts and most textbook and law review writers are seeking the same answer to the same problem.

11972–1972
Anderson v. Grasberg green
minn · 1956
2 sentences

1972It would be better if the statute were repealed so that the courts could develop rules for determining mental competency more in *36 harmony with advances made in this scientific field since the announcement of the M’Naghten rule in 1843.” In Anderson v. Grasberg, 247 Minn. 538 , 78 N. W. 2d 450 (1956), we rejected the M’Naghten rule in its application to civil cases.

1972It would be better if the statute were repealed so that the courts could develop rules for determining mental competency more in *36 harmony with advances made in this scientific field since the announcement of the M’Naghten rule in 1843.” In Anderson v. Grasberg, 247 Minn. 538 , 78 N. W. 2d 450 (1956), we rejected the M’Naghten rule in its application to civil cases.

11972–1972

Statutes the citing opinions construe

MN § Minn. Stat. § 611.026 (18) MN § Minn. Stat. § 609.185 (9) MN § Minn. Stat. § 611.025 (4) MN § Minn. Stat. § 609.19 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 66 (1964–2026) MS 57 (1968–2026) KS 45 (1960–2020) PA 45 (1955–2023) AZ 37 (1964–2018) IA 27 (1968–2024) WA 26 (1957–2023) MN 20 (1967–2026) NJ 20 (1959–2025) FL 17 (1959–2015) VA 16 (1998–2025) OK 14 (1963–2000) MD 12 (1961–1991) OR 12 (1966–2020) AK 10 (1970–2021) NV 10 (1967–2021) TX 10 (1970–2013) RI 10 (1969–2012) NC 9 (1974–1996) NE 8 (1973–2018) TN 7 (1969–1999) WI 6 (1960–2014) HI 5 (1967–2020) MA 5 (1967–2024) UT 4 (1982–1999) CO 4 (1990–1993) WV 4 (1990–2014) OH 4 (1982–2003) SC 3 (1986–1997) CT 3 (1979–1984) MT 3 (1963–1993) MI 2 (1973–2001) SD 2 (1976–1980) NM 2 (1955–1977) LA 2 (1976–1981)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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