Citation. 121 R.I. 254, 399 A.2d 469,1979 R.I. 1787, 9 A.L.R.4th 511.
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The various tests for insanity are discussed.
Synopsis of Rule of Law.
Under the now-adopted Model Penal Code test, a defendant is relieved of responsibility for his criminal actions under two circumstances: (1) when, as a result of mental disease or defect, the defendant lacked substantial capacity to appreciate the criminality of his conduct and (2) when, as a result of mental disease or defect, the defendant lacked substantial capacity to conform his conduct to the requirements of law.
Facts.
The Supreme Court of Rhode Island sets forth a history of the tests for insanity including: the M’Naghten Rule, the Irresistible Impulse Test, the Durham or “Product” Test, and the Model Penal Code Test.
Issue.
Should the Rhode Island Supreme Court abandon the M’Naghten test in favor of a new standard for determining criminal responsibility of those who claim they are blameless by reason of mental illness?
Held.
Yes. The M’Naghten Rule states that the defendant is presumed sane unless he clearly proves that, at the time of the offense, he was laboring under such a defect of reason from a disease of the mind (1) so as not to know the nature and quality of the act or (2) so as not to know the act was wrong. In response to the criticism that the M’Naghten Rule is too narrow, some states supplemented it with the Irresistible Impulse Test. Under the Irresistible Impulse Test, the M’Naghten standards are applied and then the relevant inquiry turns to: even if the defendant knew right from wrong, he is insane if (1) he is unable to control his behavior or (2) he has lost the power to choose. This test has also been widely criticized as excluding types of behavior that should not be excluded. Thereafter, the Court of Appeals for the District of Columbia diverged from the M’Naghten Rule and created the Durham or “Product” Test. Under this test, “an accused is not criminally responsible if his u
nlawful act was the product of mental disease or mental defect.” This test was ultimately abandoned, as expert witnesses essentially usurped the jury function. Finally, the Model Penal Code Test relieves the defendant of responsibility under two circumstances: (1) when, as a result of mental disease or defect, the defendant lacked substantial capacity to appreciate the criminality of his conduct and (2) when, as a result of mental disease or defect, the defendant lacked substantial capacity to conform his conduct to the requirements of law. The Supreme Court of Rhode Island chose to adopt the Model Penal Code Test, as it represents a significant, positive improvement over the M’Naghten Rule. Significantly, it acknowledges that both volitional and cognitive impairments must be considered by the jury. Also, the test employs vocabulary such that its use at trial will permit a reasonable understanding among the judges, lawyers, medical experts, and the jury.
Discussion.
It is important to understand all tests explicated in this opinion even though the majority of the states utilize either the M’Naghten Rule or the Model Penal Code Test.
