Brief Fact Summary. While the Petitioner, Crenshaw (Petitioner) and his wife were on their honeymoon in Canada, he was deported as a result of his participation in a fight. The Petitioner suspected his wife had been unfaithful in the two days since their separation and upon her return to the states he killed her in a motel room in Washington. The Petitioner testified at trial that it would be improper under his religious faith not to kill his wife if she committed adultery. The jury found the Petitioner guilty of first degree murder.
Synopsis of Rule of Law. Under the M’Naghten test for insanity, society’s morals and not an individual’s morals are the proper standard for judging moral wrong.
Held. No. Judge Brachtenbach delivered the opinion of the court. It is society’s morals, and not an individual’s morals that are the standard for judging moral wrong under M’Naghten. If moral wrong were judged by an individual’s conscience, the criminal law would be seriously undermined because it would allow a person in violation of the law to be excused from criminal responsibility merely because in his own conscience, his act was not morally wrong. There is evidence on the record that the Petitioner knew his actions were wrong according to society’s standards.
Discussion. A narrow exception to the societal standard of moral wrong occurs when an individual performs a criminal act, knows it is morally and legally wrong, but because of a mental defect believes that the act is ordained by God (i.e., God has spoken to the individual and decreed the act). This exception does not apply here because the Petitioner argued that he followed his faith and believed it was his duty to kill his wife. The Petitioner did not claim he was acting under a deific command.