insanity defense in Washington

2022App. 2d 353 , 362, 438 P.3d 582 (2019) (citing State v. Walden, 131 Wn.2d 469, 473 , 932 P.2d 1237 (1997) (justifiable homicide requires “some evidence” demonstrating self-defense or defense of another)); State v. Box, 109 Wn.2d 320, 322 , 745 P.2d 23 (1987) (an insanity instruction “require[s] a defendant to bear the initial burden of producing some evidence”); State v. Ritchey, 1 Wn.

2022App. 2d 353 , 362, 438 P.3d 582 (2019) (citing State v. Walden, 131 Wn.2d 469, 473 , 932 P.2d 1237 (1997) (justifiable homicide requires “some evidence” demonstrating self-defense or defense of another)); State v. Box, 109 Wn.2d 320, 322 , 745 P.2d 23 (1987) (an insanity instruction “require[s] a defendant to bear the initial burden of producing some evidence”); State v. Ritchey, 1 Wn.

2011When reviewing a jury's rejection of a defendant's insanity defense, we look to see whether, after "considering the evidence in the light most favorable to the State, a rational trier of fact could have found that the defendant failed to prove *161 the defense by a preponderance of the evidence." [15] Matthews, 132 Wash.App. at 941 , 135 P.3d 495 (quoting State v. Lively, 130 Wash.2d 1, 17 , 921 P.2d 1035 (1996)); accord Crenshaw, 98 Wash.2d at 802-04 , 659 P.2d 488 (affirming jury's rejection of insanity defense by reviewing trial evidence and concluding that appellant failed to meet the prep

2006In both McMachren and Brown , the reviewing courts found the evidence sufficient to support the jury’s rejection of the insanity defense. ¶9 The standard of review employed by the Georgia courts in McMachren and Brown is consistent with the standard of review our Supreme Court adopted in a similar context in State v. Lively, 130 Wn.2d 1 , 921 P.2d 1035 (1996).

2011When reviewing a jury's rejection of a defendant's insanity defense, we look to see whether, after "considering the evidence in the light most favorable to the State, a rational trier of fact could have found that the defendant failed to prove *161 the defense by a preponderance of the evidence." [15] Matthews, 132 Wash.App. at 941 , 135 P.3d 495 (quoting State v. Lively, 130 Wash.2d 1, 17 , 921 P.2d 1035 (1996)); accord Crenshaw, 98 Wash.2d at 802-04 , 659 P.2d 488 (affirming jury's rejection of insanity defense by reviewing trial evidence and concluding that appellant failed to meet the prep

2006In both McMachren and Brown , the reviewing courts found the evidence sufficient to support the jury’s rejection of the insanity defense. ¶9 The standard of review employed by the Georgia courts in McMachren and Brown is consistent with the standard of review our Supreme Court adopted in a similar context in State v. Lively, 130 Wn.2d 1 , 921 P.2d 1035 (1996).

1992Furthermore, in my opinion she fits under the insanity rule enunciated in State v. Cameron, 100 Wn.2d, 520 , (1983), which provides that a person was insane if she committed a homicide because of command hallucinations from a deity. *317 Michael Morrison, Ph.D., licensed psychologist, stated: With regard to the issue of legal sanity at the time of the alleged offense, an extensive base of information strongly suggests that Mrs. Fitzgerald was unable to appreciate the nature and quality of her actions.

1986Constitutionality of the NGI Statute Anderson claims that the not guilty by reason of insanity statute, RCW 9A.12.010, is unconstitutionally overbroad and a violation of the establishment clause of the First Amendment and of article 1, section 11 of the Washington Constitution, because State v. Cameron, 100 Wn.2d 520 , 674 P.2d 650 (1983) allowed the use of the insanity defense when the defendant claimed he was following an order from God when he killed his stepmother, even though he knew the act was legally wrong.

2021For example, in State v. Matthews, a jury rejected the defendant’s insanity defense despite four experts testifying that he was insane at the time of the offense. 132 Wn.

2011When reviewing a jury's rejection of a defendant's insanity defense, we look to see whether, after "considering the evidence in the light most favorable to the State, a rational trier of fact could have found that the defendant failed to prove *161 the defense by a preponderance of the evidence." [15] Matthews, 132 Wash.App. at 941 , 135 P.3d 495 (quoting State v. Lively, 130 Wash.2d 1, 17 , 921 P.2d 1035 (1996)); accord Crenshaw, 98 Wash.2d at 802-04 , 659 P.2d 488 (affirming jury's rejection of insanity defense by reviewing trial evidence and concluding that appellant failed to meet the prep

2018State v. Lord, 117 Wn.2d 829, 901 , 822 P.2d 177 (1991), abrogated on other grounds by State v. Schierman, 415 P.3d 106 (2018).

2014Because Mr. Halls did not raise an insanity defense, "a hearing is required only if the court makes a threshold determination that there is reason to doubt the defendant's competency." Lord, 117 Wn.2d at 901 .

2013Thus, the criminal defendant’s choice to pursue an insanity defense is “good reason for diminished concern as to the risk of error.” Id.

2005Jones, 463 U.S. at 367 . ¶22 Moreover, a defendant on trial for a felony who raises an insanity defense is necessarily competent to stand trial and possesses the capacity to participate in his or her own defense.

2013The defendant’s right to control his defense is necessary “to further the truth-seeking aim of a criminal trial and to respect individual dignity and autonomy.” State v. Coristine, 177 Wn.2d 370, 375 , 300 P.3d 400 (2013). ¶9 “Instructing the jury on an affirmative defense over the defendant’s objection violates the Sixth Amendment by interfering with the defendant’s autonomy to present a defense.”Id.; see also Jones, 99 Wn.2d at 739 (trial court violated defendant’s right to control his defense by forcing the defendant to enter a not guilty by reason of insanity plea and appointing amicus cou

2013"Instructing the JUry on an affirmative defense over the defendant's objection violates the Sixth Amendment by interfering with the defendant's -autonOmy to present -a defense.'' Ia. af375; see also Jones,-9-9 Wn.2d at 739-(trial court violated defendant's right to control his defense by forcing the defendant to enter a not guilty by reason of insanity plea and appointing amicus counsel to argue the insanity defense over defendant's objections); State v. McSorley, 128 Wn.

1990This was the language we relied upon in State v. Bonds, 98 Wn.2d 1 , 653 P.2d 1024 (1982), cert. denied, 464 U.S. 831 (1983), when we held that the Fifth Amendment does not extend to a psychiatric examination of defendant upon assertion of an insanity defense.

1990This was the language we relied upon in State v. Bonds, 98 Wn.2d 1 , 653 P.2d 1024 (1982), cert. denied, 464 U.S. 831 (1983), when we held that the Fifth Amendment does not extend to a psychiatric examination of defendant upon assertion of an insanity defense.

1990This was the language we relied upon in State v. Bonds, 98 Wn.2d 1 , 653 P.2d 1024 (1982), cert. denied, 464 U.S. 831 (1983), when we held that the Fifth Amendment does not extend to a psychiatric examination of defendant upon assertion of an insanity defense.

1990This was the language we relied upon in State v. Bonds, 98 Wn.2d 1 , 653 P.2d 1024 (1982), cert. denied, 464 U.S. 831 (1983), when we held that the Fifth Amendment does not extend to a psychiatric examination of defendant upon assertion of an insanity defense.

1982A trial judge possesses "inherent power to impose the insanity defense sua sponte over objection of defendant and his counsel." State v. Smith, 88 Wn.2d 639, 642-43 , 564 P.2d 1154 (1977).

1982A trial judge possesses "inherent power to impose the insanity defense sua sponte over objection of defendant and his counsel." State v. Smith, 88 Wn.2d 639, 642-43 , 564 P.2d 1154 (1977).

2021Over 40 years later, after the insanity defense had been codified in RCW 9A.12.010,6 our Supreme Court addressed the intersection of voluntary 6The voluntary act exception was then codified as former RCW 10.77.010(7) (1983), which provided that “[n]o condition of mind proximately induced by the voluntary act of a person charged with a crime shall constitute ‘insanity.’” 9 No. 80602-5-I/10 intoxication and insanity once again in State v. Wicks, 98 Wn.2d 620 , 657 P.2d 781 (1983).

2021Over 40 years later, after the insanity defense had been codified in RCW 9A.12.010,6 our Supreme Court addressed the intersection of voluntary 6The voluntary act exception was then codified as former RCW 10.77.010(7) (1983), which provided that “[n]o condition of mind proximately induced by the voluntary act of a person charged with a crime shall constitute ‘insanity.’” 9 No. 80602-5-I/10 intoxication and insanity once again in State v. Wicks, 98 Wn.2d 620 , 657 P.2d 781 (1983).

2021App. 936, 942 , 135 P.3d 495 (2006).

2011When reviewing a jury's rejection of a defendant's insanity defense, we look to see whether, after "considering the evidence in the light most favorable to the State, a rational trier of fact could have found that the defendant failed to prove *161 the defense by a preponderance of the evidence." [15] Matthews, 132 Wash.App. at 941 , 135 P.3d 495 (quoting State v. Lively, 130 Wash.2d 1, 17 , 921 P.2d 1035 (1996)); accord Crenshaw, 98 Wash.2d at 802-04 , 659 P.2d 488 (affirming jury's rejection of insanity defense by reviewing trial evidence and concluding that appellant failed to meet the prep

2014Scott, Jr., Handbook on Criminal Law § 45, at 347-48 (1972)). “[0]nce a defendant has shown that the degree of his involuntary intoxication meets the appropriate insanity test, his criminal capacity is vitiated and the jury never reaches the issue of specific intent.” Mriglot, 88 Wn.2d at 576 n.2.

2012Used in the nonmental element context, we stated that the term “involuntary intoxication” should be narrowly construed, id., and have opted to equate it to the insanity defense, stating that an involuntarily intoxicated defendant “is unable to perceive the nature and quality of his act or to tell right from wrong with reference to the act.” 13 Mriglot, 88 Wn.2d at 576-77 .

2013App. 598, 605 , 116 P.3d 431 (2005) (trial court violated defendant’s right to control his defense by instructing the jury on an affirmative defense to the crime of child luring over defendant’s objection). ¶10 This court’s recent decision in Coristine is dispositive in resolving this case.

2013App. 598, 605 , 116 P.3d 431 (2005) (trial court violated defendant's right to control his defense by instructing the jury on an affirmative defense to the crime of child luring over defendant's objection).