People v. Serravo

Brief Fact Summary.

In Serravo (Defendant’s) trial for attempted first-degree murder, Defendant presented an insanity defense based upon his belief that God wanted him to assault his wife. The trial court gave a jury instruction on the defense of insanity that the State objected to and appealed.

Synopsis of Rule of Law.

Under the M’Naghten rule, a defendant is legally considered insane when he cannot distinguish right from moral, as opposed to legal, wrong.

Facts.

Defendant believed that God wanted him to construct a sports complex. After discussing his plans with co-workers and believing they supported his project, Defendant went home and stabbed his wife. Defendant told his wife and the police that an intruder had stabbed her, but his wife then found letters Defendant had written discussing his plan to stab his wife based on instructions from God. Defendant’s wife informed the police of his letters and Defendant was arrested and charged with attempted first-degree murder and first-degree assault. During a psychiatric evaluation, Defendant said that he did not think his wife supported his plan to build the sports complex and that “evil spirits” inside of him were telling him how to handle his wife’s lack of support. At trial, the prosecution presented psychiatric testimony that Defendant had a delusional disorder resulting from brain damage sustained in a car accident years before but that he was sane at the time of the assault. The defense presented psychiatric testimony that Defendant was suffering from a paranoid delusion at the time of the crime and could not tell right from wrong. The trial court gave a jury instruction that suggested that Defendant would be considered legally insane if he believed that the act he was committing was morally right. The jury found Defendant not guilty and the State appealed, arguing that the defense of insanity should be based upon legal, not moral, grounds. The intermediate appellate court affirmed the trial court decision, and added that the moral standard be based upon a prevailing societal standard of morality. The State further appealed.

Issue.

Is a defendant considered legally insane under the M’Naghten rule when he cannot distinguish right from moral, as opposed to legal, wrong?

Held.

(Quinn, J.) Yes. Under the M’Naghten rule, a defendant is legally considered insane when he cannot distinguish right from moral, as opposed to legal, wrong. This state applies the M’Naghten rule in defining insanity as the inability to distinguish between right and wrong. M’Naghten suggests that a person is legally sane when he commits an act which he knows to be morally wrong. Other courts applying M’Naghten have also rejected the idea that the term “wrong” refers to illegal acts, or legal wrongs. Basing the definition of “wrong” on “legal wrongs” ignores a critical psychological component in applying the legal definition of insanity. Our holding does not extend to moral views that are merely different from those that underlie the laws of the state. It applies only to mentally ill defendants who commit acts that they are aware are contrary to the law, but commit anyway. The definition of “moral” can be found either in an objectively reasonable societal standard or in the subjective moral beliefs of the defendant. However, defining it through the subjective standard would ignore a part of social morality upon which acceptable behavior relies. The word “wrong” as used in the state’s definition of insanity refers to moral and not legal wrong. We also affirm the court of appeals’ definiton of moral wrong as based on an objective social standard rather than a subjective one. The trial court’s finding of not guilty by reason of insanity is affirmed.

Discussion.

The court spends time on the distinction between objective and subjective standards of morality. However, the M’Naghten rule was originally intended to apply only to a defendant’s understanding of the legality of the act committed, and not to its morality under prevailing societal standards. The ruling in this case allows those who disagree with the morality of the established law to raise the defense. Although such a person may be insane, the court did not address here the analysis needed to account for both legally and morally culpable defendants.