Brief Fact Summary. The Appellant, Guido (Appellant), was convicted of second degree murder for killing her husband. The Appellant was subjected to physical and emotional abuse by her husband and was generally afraid of him. Defense counsel debated with expert witnesses over their reports pertaining to the interpretation of “disease of the mind” as it relates to the definition of legal insanity. During the trial, prosecutors alleged that defense counsel persuaded the expert witnesses to change their reports in order to obtain a more favorable outcome for his client.
Synopsis of Rule of Law. Although the main emphasis for what constitutes a “disease of the mind” under M’Naghten concerns the actual state of mind, there is no concrete definition and the definition of legal insanity is up for debate.
Held. Judgment of the lower court is reversed. Chief Judge C.J. Weintraub delivered the opinion of the court. When the issue surrounding the change in the expert witnesses’ report was investigated, the change was decidedly made in all honesty. There was a debate over what the doctors understood to be the definition of “disease of the mind” under M’Naghten. The doctors thought it meant psychosis and not a lesser illness or aberration of the mind. While their prior medical findings remained the same, there was a change in the witnesses’ understanding of what the law means by “disease.” Ultimately, the doctors concluded they had too narrow a view of M’Naghten. Therefore, they concluded that Appellant’s diagnosed “anxiety neurosis” qualified as a disease within the legal rule.
Discussion. There is a widespread reluctance to define what is meant by “disease” under the M’Naghten rule. Because there is no concrete definition, the definition of what constitutes legal insanity is up for discussion.