M'Naghten test in Pennsylvania

45 Pennsylvania opinions name it 4 courts 1955–2023 2 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 (38)

Case	Followed	Cited
Commonwealth v. Demmittgreen pa · 1974 · cited in 14 Pennsylvania opinions naming this issue, 1974–1989 2 sentences 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975). 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975).	5	14
Commonwealth v. Hamiltongreen pa · 1974 · cited in 7 Pennsylvania opinions naming this issue, 1976–2023 2 sentences 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975). 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975).	4	7
Commonwealth v. Walzackgreen pa · 1976 · cited in 6 Pennsylvania opinions naming this issue, 1979–2022 2 sentences 2022See 18 Pa.C.S.A. § 315(a); see also Commonwealth v. Walzack, 360 A.2d 914, 916 (Pa. 1976) (“[T]oday’s decision in no way affects the vitality of the M’Naghten test as the sole standard in this Commonwealth for determining criminal responsibility where the actor alleges mental illness or defect) (footnoted omitted, emphasis added). 1990Cf. Commonwealth v. Walzack, supra, 468 Pa. at 213-14 , 360 A.2d at 916 ("today’s decision in no way affects the vitality of the M’Naghten test as the sole standard in this Commonwealth for determining criminal responsibility where the actor alleges mental illness or defect.”) (footnote omitted) (emphasis supplied).	4	6
Commonwealth v. Woodhousegreen pa · 1960 · cited in 6 Pennsylvania opinions naming this issue, 1974–1990 2 sentences 1984The M’Naghten test of insanity relieves a defendant of criminal responsibility for his actions if at the time he committed a crime he was 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 he did know it, that he did not know he was doing wrong.” Commonwealth v. Woodhouse, 401 Pa. 242 , 164 A.2d 98 (1960). . 1984The M’Naghten test of insanity relieves a defendant of criminal responsibility for his actions if at the time he committed a crime he was 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 he did know it, that he did not know he was doing wrong.” Commonwealth v. Woodhouse, 401 Pa. 242 , 164 A.2d 98 (1960). .	3	6
Commonwealth v. Brunogreen pa · 1976 · cited in 6 Pennsylvania opinions naming this issue, 1978–1981 2 sentences 1981Commonwealth v. Bruno, 466 Pa. 245 , 352 A.2d 40 (1976); Commonwealth v. Tyson, supra. The M’Naghten test can embrace those mentally disturbed in the category of those criminally responsible. 1981Commonwealth v. Bruno, 466 Pa. 245 , 352 A.2d 40 (1976); Commonwealth v. Tyson, supra. The M’Naghten test can embrace those mentally disturbed in the category of those criminally responsible.	3	6
Clark v. Arizonagreen scotus · 2006 · cited in 3 Pennsylvania opinions naming this issue, 2008–2015 2 sentences 2015As the majority of the United States Supreme Court reasoned in Clark v. Arizona, 548 U.S. 735 (2006), in distinguishing between the cognitive incapacity and moral incapacity prongs of the M'Naghten test, “In practical terms, if a defendant did not know what he was doing when he acted, he could not have known that he was performing the wrongful act charged as a crime.” Clark, supra at 753–754; see also id., at 768 n. 38 (“Not only does evidence accepted as showing insanity trump mens rea, but evidence of behavior close to the time of the act charged may indicate both the actual state of mind at 2015As the majority of the United States Supreme Court reasoned in Clark v. Arizona, 548 U.S. 735 (2006), in distinguishing between the cognitive incapacity and moral incapacity prongs of the M'Naghten test, “In practical terms, if a defendant did not know what he was doing when he acted, he could not have known that he was performing the wrongful act charged as a crime.” Clark, supra at 753–754; see also id., at 768 n. 38 (“Not only does evidence accepted as showing insanity trump mens rea, but evidence of behavior close to the time of the act charged may indicate both the actual state of mind at	3	3
Commonwealth v. Moslergreen pa · 1846 · cited in 7 Pennsylvania opinions naming this issue, 1976–1999 2 sentences 1999In support of this argument, appellant asks this court to conclude that the decision of Commonwealth v. Trill, 374 Pa.Super. 549 , 543 A.2d 1106 (1988), appeal denied, 522 Pa. 603 , 562 A.2d 826 (1989) was wrongly decided, and to seek guidance from the interpretations of courts in other jurisdictions of their own statutes relating to insanity and mental illness. ¶ 22 We first point out that this Commonwealth has been consistent in its application of the M’Naghten rule since Commonwealth v. Mosler, 4 Pa. 264 (1846). 9 Commonwealth v. Reilly, 519 Pa. 550 , 549 A.2d 503 (1988). 1999In support of this argument, appellant asks this court to conclude that the decision of Commonwealth v. Trill, 374 Pa.Super. 549 , 543 A.2d 1106 (1988), appeal denied, 522 Pa. 603 , 562 A.2d 826 (1989) was wrongly decided, and to seek guidance from the interpretations of courts in other jurisdictions of their own statutes relating to insanity and mental illness. ¶ 22 We first point out that this Commonwealth has been consistent in its application of the M’Naghten rule since Commonwealth v. Mosler, 4 Pa. 264 (1846). 9 Commonwealth v. Reilly, 519 Pa. 550 , 549 A.2d 503 (1988).	2	7
Commonwealth v. Reillygreen pa · 1988 · cited in 3 Pennsylvania opinions naming this issue, 1989–2008 2 sentences 2008Further, the M’Naghten test for insanity, adopted by the Pennsylvania Legislature, has applied on a long-standing basis in Pennsylvania, see Commonwealth v. Reilly, 519 Pa. 550, 558-59 , 549 A.2d 503, 507 (1988); this “right-and-wrong” test has been deemed consistent with due process, see Clark, 548 U.S. at 753 , 126 S.Ct. at 2722 ; it has long been accepted that criminal defendants may be presumed sane for purposes of determining their criminal liability, see 365 id. at 766 , 126 S.Ct. at 2729-30 (“The presumption of sanity is equally universal in some variety or other, being (at least) a pr 2008Further, the M’Naghten test for insanity, adopted by the Pennsylvania Legislature, has applied on a long-standing basis in Pennsylvania, see Commonwealth v. Reilly, 519 Pa. 550, 558-59 , 549 A.2d 503, 507 (1988); this “right-and-wrong” test has been deemed consistent with due process, see Clark, 548 U.S. at 753 , 126 S.Ct. at 2722 ; it has long been accepted that criminal defendants may be presumed sane for purposes of determining their criminal liability, see 365 id. at 766 , 126 S.Ct. at 2729-30 (“The presumption of sanity is equally universal in some variety or other, being (at least) a pr	2	3
Commonwealth v. Meltongreen pa · 1962 · cited in 3 Pennsylvania opinions naming this issue, 1972–1976 2 sentences 1976See, e.g., Commonwealth v. Melton, 406 Pa. 343 , 178 A.2d 728 (1962), cert. denied, 371 U.S. 851 , 83 S.Ct. 93 , 9 L. 1976See, e.g., Commonwealth v. Melton, 406 Pa. 343 , 178 A.2d 728 (1962), cert. denied, 371 U.S. 851 , 83 S.Ct. 93 , 9 L.	2	3
Commonwealth v. Robertsgreen pa · 1981 · cited in 2 Pennsylvania opinions naming this issue, 1984–1990 2 sentences 1990Compare, e.g., Commonwealth v. Roberts, 496 Pa. 428, 434 , 437 A.2d 948, 951 (1981) (quoting Commonwealth v. 343 Woodhouse, 401 Pa. 242, 249-50 , 164 A.2d 98, 103 (1960); Regina v. M’Naghten, 10 Cl. & Fin. 200, 8 Eng.Rep. 718 (1843)). 3 . 1990Compare, e.g., Commonwealth v. Roberts, 496 Pa. 428, 434 , 437 A.2d 948, 951 (1981) (quoting Commonwealth v. 343 Woodhouse, 401 Pa. 242, 249-50 , 164 A.2d 98, 103 (1960); Regina v. M’Naghten, 10 Cl. & Fin. 200, 8 Eng.Rep. 718 (1843)). 3 .	2	2
Phillips v. Oklahomagreen scotus · 1975 · cited in 4 Pennsylvania opinions naming this issue, 1976–1980 2 sentences 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975). 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975).	1	4
Jordan v. Colbertgreen scotus · 1975 · cited in 4 Pennsylvania opinions naming this issue, 1976–1980 2 sentences 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975). 1980The test in Pennsylvania for determining legal insanity is the M’Naghten test: “[A] defendant is legally insane if, ‘at the time of the act, either he did not know the nature and quality of the act or he did not know that it was wrong.’ ” Commonwealth v. Bruno, 466 Pa. 245, 251 , 352 A.2d 40, 43 (1976), quoting Commonwealth v. Demmitt, supra, 457 Pa. at 481 , 321 A.2d at 631 ; see Commonwealth v. Tyson, 485 Pa. 344 , 402 A.2d 995 (1979); Commonwealth v. Hamilton, 459 Pa. 304 , 329 A.2d 212 (1974), cert. denied, 420 U.S. 981 , 95 S.Ct. 1411 , 43 L.Ed.2d 663 (1975).	1	4
Commonwealth v. Hicksgreen pa · 1979 · cited in 3 Pennsylvania opinions naming this issue, 1981–1982 2 sentences 1981We reject appellant’s argument and rely on our Supreme Court’s recent reaffirmation of the M’Naghten test in Commonwealth v. Hicks, 483 Pa. 305 , 396 A.2d 1183 (1979). 1981We reject appellant’s argument and rely on our Supreme Court’s recent reaffirmation of the M’Naghten test in Commonwealth v. Hicks, 483 Pa. 305 , 396 A.2d 1183 (1979).	1	3
Battalino v. Peoplegreen colo · 1948 · cited in 3 Pennsylvania opinions naming this issue, 1966–1976 2 sentences 1976See, also, Battalino v. People, 118 Colo. 587 , 199 P.2d 897 (1948); Leick v. People, 131 Colo. 353 , 281 P.2d 806 (1955). 1976See, also, Battalino v. People, 118 Colo. 587 , 199 P.2d 897 (1948); Leick v. People, 131 Colo. 353 , 281 P.2d 806 (1955).	1	3
Commonwealth v. Tempestgreen pa · 1981 · cited in 2 Pennsylvania opinions naming this issue, 1987–1989 2 sentences 1987In Commonwealth v. Tempest, supra, we stated that the M’Naghten test can and does embrace those mentally disturbed in the category of those criminally responsible, 496 Pa. at 441, 437 A.2d 952 , and is not intended to separate the emotionally disturbed from the emotionally healthy. 1987In Commonwealth v. Tempest, supra, we stated that the M’Naghten test can and does embrace those mentally disturbed in the category of those criminally responsible, 496 Pa. at 441, 437 A.2d 952 , and is not intended to separate the emotionally disturbed from the emotionally healthy.	1	2
Melton v. Pennsylvaniagreen scotus · 1962 · cited in 2 Pennsylvania opinions naming this issue, 1972–1976 2 sentences 1976See, e.g., Commonwealth v. Melton, 406 Pa. 343 , 178 A.2d 728 (1962), cert. denied, 371 U.S. 851 , 83 S.Ct. 93 , 9 L. 1976See, e.g., Commonwealth v. Melton, 406 Pa. 343 , 178 A.2d 728 (1962), cert. denied, 371 U.S. 851 , 83 S.Ct. 93 , 9 L.	1	2
Eastman v. New Yorkgreen scotus · 1962 · cited in 2 Pennsylvania opinions naming this issue, 1972–1976 2 sentences 1976See, e.g., Commonwealth v. Melton, 406 Pa. 343 , 178 A.2d 728 (1962), cert. denied, 371 U.S. 851 , 83 S.Ct. 93 , 9 L. 1976See, e.g., Commonwealth v. Melton, 406 Pa. 343 , 178 A.2d 728 (1962), cert. denied, 371 U.S. 851 , 83 S.Ct. 93 , 9 L.	1	2
Commonwealth v. Faulknergreen pa · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023 2 sentences 2023Id. at 35.2 ____________________________________________ 2“A person who timely offers a defense of insanity in accordance with the Rules of Criminal Procedure may be found ‘guilty but mentally ill’ at trial if the (Footnote Continued Next Page) -9- J-S18041-23 On appeal, the Supreme Court affirmed the trial court’s ruling, stating that “[t]estimony from psychiatric experts is relevant if it can establish that the defendant was insane under the M’Naghten standard … or to negate specific intent to commit first degree murder.” Id. at 36. 2023Id. at 35.2 ____________________________________________ 2“A person who timely offers a defense of insanity in accordance with the Rules of Criminal Procedure may be found ‘guilty but mentally ill’ at trial if the (Footnote Continued Next Page) -9- J-S18041-23 On appeal, the Supreme Court affirmed the trial court’s ruling, stating that “[t]estimony from psychiatric experts is relevant if it can establish that the defendant was insane under the M’Naghten standard … or to negate specific intent to commit first degree murder.” Id. at 36.	1	1
Commonwealth v. Raboldgreen pa · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023	1	1
Nationwide Mutual Insurance v. Hassingergreen pa · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019	1	1
Commonwealth v. Santiagogreen pa · 2004 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008	1	1
Commonwealth v. Freygreen pa · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008	1	1
Commonwealth v. Henrygreen pa · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008	1	1
Commonwealth v. Zewegreen pasuperct · 1995 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999	1	1
Gary Lee Rock v. Leroy S. Zimmerman John F. Nelson, District Attorney of Franklin Countygreen ca3 · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999	1	1
Rock v. Preategreen scotus · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999	1	1
Aviation Associates, Inc. v. Airline Pilots Ass'n Internationalgreen scotus · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999	1	1
Shore v. Commissionergreen scotus · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999	1	1
Commonwealth v. Zettlemoyergreen pa · 1982 · cited in 1 Pennsylvania opinions naming this issue, 1995–1995	1	1
Rolls-Royce Ltd. v. Nallsgreen scotus · 1983 · cited in 1 Pennsylvania opinions naming this issue, 1995–1995	1	1
Commonwealth v. Weinsteingreen pa · 1982 · cited in 1 Pennsylvania opinions naming this issue, 1990–1990	1	1
Commonwealth v. Banksgreen pa · 1987 · cited in 1 Pennsylvania opinions naming this issue, 1989–1989	1	1
Commonwealth v. Tysongreen pa · 1979 · cited in 1 Pennsylvania opinions naming this issue, 1980–1980	1	1
Commonwealth v. Tomlinsongreen pa · 1971 · cited in 1 Pennsylvania opinions naming this issue, 1976–1976	1	1
Commonwealth v. Robsongreen pa · 1975 · cited in 1 Pennsylvania opinions naming this issue, 1976–1976	1	1
Commonwealth v. Boydgreen pa · 1975 · cited in 1 Pennsylvania opinions naming this issue, 1976–1976	1	1
People v. Welborngreen calctapp · 1967 · cited in 1 Pennsylvania opinions naming this issue, 1974–1974	1	1
Commonwealth v. Carluccettigreen pa · 1952 · cited in 1 Pennsylvania opinions naming this issue, 1955–1955	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (32)

Case	Cited	Years
Commonwealth v. McCusker green pa · 1972 2 sentences 1976In Commonwealth v. McCusker, supra, after noting many of the areas in criminal law where we have accepted a psychiatrist's opinion we observed: ". . . [t]he reliance we have consistently placed upon the competence of psychiatric evidence belies any concern that it is not a sufficiently recognized and accepted medical science capable of offering quality expert guidance." Id. at 392 , 292 A.2d at 291 . [9] We have long accepted psychiatric evidence on the issue of whether an accused is competent to stand trial. [10] Similarly, we have long permitted psychiatric evidence under the M'Naghten test 1976In Commonwealth v. McCusker, supra, after noting many of the areas in criminal law where we have accepted a psychiatrist's opinion we observed: ". . . [t]he reliance we have consistently placed upon the competence of psychiatric evidence belies any concern that it is not a sufficiently recognized and accepted medical science capable of offering quality expert guidance." Id. at 392 , 292 A.2d at 291 . [9] We have long accepted psychiatric evidence on the issue of whether an accused is competent to stand trial. [10] Similarly, we have long permitted psychiatric evidence under the M'Naghten test	3	1974–1976
Germantown Insurance v. Martin green pasuperct · 1991 2 sentences 2009The court refused to consider irrelevant psychiatric evidence since it did not address the M’Naghten test (which is the appropriate standard to determine mental incapacity in criminal and civil cases), and opined generally that courts should not “[delve] into the subjective state of mind or rationality of the actor” because it sought to avoid disputes between expert witnesses “one of whom can be found to testify on any position.” Id. at 334 , 595 A.2d at 1176 . 2009The court refused to consider irrelevant psychiatric evidence since it did not address the M’Naghten test (which is the appropriate standard to determine mental incapacity in criminal and civil cases), and opined generally that courts should not “[delve] into the subjective state of mind or rationality of the actor” because it sought to avoid disputes between expert witnesses “one of whom can be found to testify on any position.” Id. at 334 , 595 A.2d at 1176 .	2	2009–2019
Commonwealth v. Ernst green pa · 1977 2 sentences 1980Commonwealth v. Ernst, 476 Pa. 102 , 381 A.2d 1245 (1977); Commonwealth v. Whitfield, 475 Pa. 297 , 380 A.2d 362 (1977). 1980Commonwealth v. Ernst, 476 Pa. 102 , 381 A.2d 1245 (1977); Commonwealth v. Whitfield, 475 Pa. 297 , 380 A.2d 362 (1977).	2	1978–1980
Commonwealth v. Whitfield green pa · 1977 2 sentences 1980Commonwealth v. Ernst, 476 Pa. 102 , 381 A.2d 1245 (1977); Commonwealth v. Whitfield, 475 Pa. 297 , 380 A.2d 362 (1977). 1980Commonwealth v. Ernst, 476 Pa. 102 , 381 A.2d 1245 (1977); Commonwealth v. Whitfield, 475 Pa. 297 , 380 A.2d 362 (1977).	2	1978–1980
Brose Estate green pa · 1966 2 sentences 1976See, e. g., Commonwealth v. Tomlinson, 446 Pa. 241 , 284 A.2d 687 (1971); Commonwealth v. Ahearn, 421 Pa. 311 , 218 A.2d 561 (1966). 1976See, e. g., Commonwealth v. Tomlinson, 446 Pa. 241 , 284 A.2d 687 (1971); Commonwealth v. Ahearn, 421 Pa. 311 , 218 A.2d 561 (1966).	2	1974–1976
Commonwealth v. Ahearn green pa · 1966 2 sentences 1976See, e. g., Commonwealth v. Tomlinson, 446 Pa. 241 , 284 A.2d 687 (1971); Commonwealth v. Ahearn, 421 Pa. 311 , 218 A.2d 561 (1966). 1976See, e. g., Commonwealth v. Tomlinson, 446 Pa. 241 , 284 A.2d 687 (1971); Commonwealth v. Ahearn, 421 Pa. 311 , 218 A.2d 561 (1966).	2	1974–1976
State v. DiPaolo green nj · 1961 2 sentences 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949) ; Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the ‘science’ of psychiatry when one considers the universal acceptance 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949); Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the `science' of psychiatry when one considers the universal acceptance	2	1966–1974
People v. Wells green cal · 1949 2 sentences 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949) ; Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the ‘science’ of psychiatry when one considers the universal acceptance 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949); Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the `science' of psychiatry when one considers the universal acceptance	2	1966–1974
People v. Henderson green cal · 1963 2 sentences 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949) ; Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the ‘science’ of psychiatry when one considers the universal acceptance 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949); Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the `science' of psychiatry when one considers the universal acceptance	2	1966–1974
People v. Gorshen green cal · 1959 2 sentences 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949) ; Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the ‘science’ of psychiatry when one considers the universal acceptance 1974See, e.g., California decisions: People v. Henderson, 386 P. 2d 677 (1963); People v. Gorshen, 336 P. 2d 492 (1959); People v. Wells, 202 P. 2d 53 (1949); Iowa: State v. Gramenz, 126 N.W. 2d 285 (1964); Colorado: Battalino v. People, 199 P. 2d 897 (1948) (containing many other cases); New Jersey: State v. DiPaolo, 168 A. 2d 401 (1961). (3) The evidence cannot be excluded on the basis of the general unreliability (as opposed to lack of weight in a particular case because of cross-examination or lack of foundation, etc.) of the `science' of psychiatry when one considers the universal acceptance	2	1966–1974
State v. Gramenz green iowa · 1964 2 sentences 1974For a discussion of the adoption of the rule in Pennsylvania, see Commonwealth v. Woodhouse, 401 Pa. 242 , 164 A.2d 98 (1960). [3] See, e.g., Commonwealth v. Heller, 369 Pa. 457 , 87 A.2d 287 (1952), for a discussion of the M'Naghten test using this language. [4] See Commonwealth v. Vogel, 440 Pa. 1 , 268 A.2d 89 (1970) (opinion by Justice, now Chief Justice, JONES) for an analysis of the relation of the element of intent to the insanity defense. [5] See State v. Gramenz, 256 Iowa 134 , 126 N.W.2d 285 (1964). 1974For a discussion of the adoption of the rule in Pennsylvania, see Commonwealth v. Woodhouse, 401 Pa. 242 , 164 A.2d 98 (1960). [3] See, e.g., Commonwealth v. Heller, 369 Pa. 457 , 87 A.2d 287 (1952), for a discussion of the M'Naghten test using this language. [4] See Commonwealth v. Vogel, 440 Pa. 1 , 268 A.2d 89 (1970) (opinion by Justice, now Chief Justice, JONES) for an analysis of the relation of the element of intent to the insanity defense. [5] See State v. Gramenz, 256 Iowa 134 , 126 N.W.2d 285 (1964).	2	1966–1974
Commonwealth v. Vogel green pa · 1970 2 sentences 1974For a discussion of the adoption of the rule in Pennsylvania, see Commonwealth v. Woodhouse, 401 Pa. 242 , 164 A.2d 98 (1960). [3] See, e.g., Commonwealth v. Heller, 369 Pa. 457 , 87 A.2d 287 (1952), for a discussion of the M'Naghten test using this language. [4] See Commonwealth v. Vogel, 440 Pa. 1 , 268 A.2d 89 (1970) (opinion by Justice, now Chief Justice, JONES) for an analysis of the relation of the element of intent to the insanity defense. [5] See State v. Gramenz, 256 Iowa 134 , 126 N.W.2d 285 (1964). 1974For a discussion of the adoption of the rule in Pennsylvania, see Commonwealth v. Woodhouse, 401 Pa. 242 , 164 A.2d 98 (1960). [3] See, e.g., Commonwealth v. Heller, 369 Pa. 457 , 87 A.2d 287 (1952), for a discussion of the M'Naghten test using this language. [4] See Commonwealth v. Vogel, 440 Pa. 1 , 268 A.2d 89 (1970) (opinion by Justice, now Chief Justice, JONES) for an analysis of the relation of the element of intent to the insanity defense. [5] See State v. Gramenz, 256 Iowa 134 , 126 N.W.2d 285 (1964).	2	1974–1974
Stidham v. Millvale Sportsmen's Club green pasuperct · 1992	1	2009–2009
Leland v. Oregon green scotus · 1952	1	2008–2008
Commonwealth v. Trill green pa · 1988	1	1999–1999
Commonwealth v. Sohmer green pa · 1988	1	1999–1999
Commonwealth v. Eck green pasuperct · 1995	1	1999–1999
Commonwealth v. Oblek green pa · 1981	1	1987–1987
Commonwealth v. Scarborough green pa · 1980	1	1982–1982
Commonwealth v. Pifer green pasuperct · 1981	1	1981–1981
Commonwealth v. Norman green pasuperct · 1978	1	1980–1980
Commonwealth v. Rose green pa · 1974	1	1980–1980
Commonwealth v. Vogel green pa · 1976	1	1979–1979
Commonwealth v. Harper green pa · 1978	1	1978–1978
Beckstead v. People green colo · 1956	1	1976–1976
Leick v. People green colo · 1955	1	1976–1976
Commonwealth v. Murray green pa · 1975	1	1976–1976
Commonwealth v. Heller green pa · 1952	1	1974–1974
United States v. Archie W. Brawner green cadc · 1972	1	1974–1974
State v. Green green utah · 1931	1	1974–1974
Commonwealth v. Jordan green pa · 1962	1	1974–1974
Commonwealth v. Elliott green pa · 1952	1	1971–1971

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 2502 (7) PA § 18 Pa. Cons. Stat. § 314 (6) PA § 18 Pa. Cons. Stat. § 315 (5) PA § 42 Pa. Cons. Stat. § 9727 (5) PA § 18 Pa. Cons. Stat. § 2701 (3) PA § 18 Pa. Cons. Stat. § 2702 (3) PA § 42 Pa. Cons. Stat. § 9711 (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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