At the time of the index offense the defendant was laboring under such a defect of reason, from disease of the mind, that the offender did not know the nature and quality of the crime he or she was committing (2). If they defendant did know understand the nature and quality of the offense, the defendant failed to realize what he was doing was wrong. (Butler, 2011). Moving forward, the M'Naghten rule became the standard for insanity in the United Kingdom and the United States; it is still the standard for insanity in almost half of the states.
Circumstances of Index Offense .
During the early hours of June 21, 2000, Eric Clark, a seventeen-year-old armed with a firearm, circled a Flagstaff, Arizona neighborhood in his pickup truck blaring loud music. Officer Jeffery Moritz received several noise complaints and responded to the scene; in uniform. Moritz pulled Clark over in his marked patrol car with his emergency lights on, and asked Clark to remain in his car. In less than a minute, Clark had shot and killed Moritz, and fled to scene. Shortly thereafter, Clark was charged with first-degree murder for intentionally and or knowingly killing a police officer in the line of duty. At trial, Clark asserted a defense of Guilty Except Sane (GES) under Arizona Revised Statue § 13-502(1996). Clark claimed that he suffered from paranoid schizophrenia and believed the police officer was an alien, and was therefore plagued with a mental disease or defect of such severity that he did not know the criminal act was wrong. Ultimately, Clark was determined to have failed to meet his burden of clear and convincing evidence, and subsequently found guilty of first-degree murder in 2003. In 2005, Clark's conviction was upheld by the Court of Appeals. .
Clark v. Arizona, 548 U.S. 735 (2006).
In hearing Clark v. Arizona (docket 05-5966), the US Supreme Court considered a direct challenge to Arizona's insanity defense.
