legal insanity defense (Pennsylvania) · Go Syfert
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legal insanity defense in Pennsylvania

8 Pennsylvania opinions name it 2 courts 1998–2025 5 in the last five years

The cases below were cited by Pennsylvania 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 (6)

CaseFollowedCited
Com. v. Fortune, L.green
pasuperct · 2023 · cited in 3 Pennsylvania opinions naming this issue, 2025–2025
2 sentences

2025Appellant further asserts that, - 12 - if counsel informed him that he could have lodged a legal insanity defense at trial, he would not have entered a guilty plea in this matter.3 “An insanity defense focuses upon a defendant's capacity, at the time of the offense, to understand the nature and quality of his actions or whether he knew that his actions were wrong.” Commonwealth v. Fortune, 302 A.3d 780, 784 (Pa. Super. 2023) (citation omitted).

2025Appellant further asserts that, - 12 - if counsel informed him that he could have lodged a legal insanity defense at trial, he would not have entered a guilty plea in this matter.3 “An insanity defense focuses upon a defendant's capacity, at the time of the offense, to understand the nature and quality of his actions or whether he knew that his actions were wrong.” Commonwealth v. Fortune, 302 A.3d 780, 784 (Pa. Super. 2023) (citation omitted).

33
Commonwealth v. Andregreen
pasuperct · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2017–2019
2 sentences

2019“Indeed, unless a person pleads guilty but mentally ill, the guilty but mentally ill verdict only arises in the context of a legal insanity defense.” Andre, 17 A.3d at 961 (Pa. Super. 2011).

2017We implied as much in Commonwealth v. Andre, 17 A.3d 951 (Pa. Super. 2011), where we said that, “unless a person pleads guilty but mentally ill, the guilty but mentally ill verdict only arises in the context of a legal insanity defense.” 17 A.3d at 961 (emphasis added; explaining interplay among mens rea, insanity, and guilty but mentally ill).

22
Commonwealth v. Raineygreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022“To establish a diminished capacity defense, a defendant must prove that his cognitive abilities of deliberation and premeditation were so compromised, by mental defect or voluntary intoxication, that he was unable to formulate the specific intent to kill.” Commonwealth Hutchinson, 25 A.3d 277, 312 (Pa. 2011) (citing Commonwealth v. Rainey, 928 A.2d 215, 237 (Pa. 2007), and Commonwealth v. Spotz, 896 A.2d 1191, 1218 (Pa. 2006)).

11
Commonwealth v. Spotzgreen
pa · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022“To establish a diminished capacity defense, a defendant must prove that his cognitive abilities of deliberation and premeditation were so compromised, by mental defect or voluntary intoxication, that he was unable to formulate the specific intent to kill.” Commonwealth Hutchinson, 25 A.3d 277, 312 (Pa. 2011) (citing Commonwealth v. Rainey, 928 A.2d 215, 237 (Pa. 2007), and Commonwealth v. Spotz, 896 A.2d 1191, 1218 (Pa. 2006)).

11
Commonwealth v. Hutchinsongreen
pa · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022“To establish a diminished capacity defense, a defendant must prove that his cognitive abilities of deliberation and premeditation were so compromised, by mental defect or voluntary intoxication, that he was unable to formulate the specific intent to kill.” Commonwealth Hutchinson, 25 A.3d 277, 312 (Pa. 2011) (citing Commonwealth v. Rainey, 928 A.2d 215, 237 (Pa. 2007), and Commonwealth v. Spotz, 896 A.2d 1191, 1218 (Pa. 2006)).

11
Commonwealth v. Younggreen
pa · 1990 · cited in 1 Pennsylvania opinions naming this issue, 1998–1998
2 sentences

1998See Commonwealth v. Young, 524 Pa. 373 , 392 n. 3, 572 A.2d 1217 , 1227 n. 3 (1990); Pennsylvania Suggested Standard Criminal Jury instructions 5.01 A(6) (guilty but mentally ill becomes a possible verdict only when a defendant offers but fails to prove a legal insanity defense).

1998See Commonwealth v. Young, 524 Pa. 373 , 392 n. 3, 572 A.2d 1217 , 1227 n. 3 (1990); Pennsylvania Suggested Standard Criminal Jury instructions 5.01 A(6) (guilty but mentally ill becomes a possible verdict only when a defendant offers but fails to prove a legal insanity defense).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Commonwealth v. Rabold green
pa · 2008
1 sentence

2023As this Court has explained, a defendant may successfully assert a legal insanity defense when he shows that “at the time of the commission of the offense, the actor was laboring under such a defect of reason, from disease of the mind, as not to know the nature and quality of the act he was doing or, if…what he was doing was wrong.” Rabold, supra at 347-48, 951 A.2d at 331 (quoting 18 Pa.C.S.A. § 315). - 26 - At trial, during the Commonwealth’s direct examination of Dr. O’Brien, the prosecutor asked the following: Q: Doctor, you’ve mentioned the different diagnosis [Appellant has] received ove

12023–2023

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 314 (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

PA 8 (1998–2025) MI 6 (1986–2026) WV 3 (1979–1984)

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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