State v. Crenshaw

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.

Facts. While the Petitioner and his wife were on their honeymoon in Canada, he was deported as a result of his participation in a fight. Crenshaw waited for the arrival of his wife in Washington in a motel room. He suspected his wife had been unfaithful in the two days since their separation, but did not question her about his suspicions. Upon her return to the states, he beat her unconscious and then went to a nearby store where he obtained a knife. The Petitioner then proceeded to stab her multiple times and decapitated her with an ax from a nearby farm where he was employed. He then tried to conceal his actions by placing her body in a blanket in his car, cleaning the motel room, and chatting with the motel manager over a beer before leaving. After leaving the motel, he hid the body in a remote area and picked up two hitchhikers who later turned him into the police after he told them about his wife. After confessing to the police, 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. The Petitioner contends that the trial court erred in defining “right and wrong” as legal right and wrong rather than in a moral sense.

Issue. Did the trial court err in defining “right and wrong” as a legal right and wrong instead of in the moral sense?

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.