State v. Crenshaw
98 Wash.2d 789, 659 P.2d 488 (1983)

  • Crenshaw was on vacation with his wife and decided she’d be unfaithful. So he beat her to death and chopped her up with an axe. Then he cleaned the blood out of the hotel room, and enlisted some hitchhikers to help him dispose the body. They turned him into the police instead.
  • The police arrested Crenshaw and charged him with first-degree murder.
  • Crenshaw confessed to the crime, but pled not guilty by reason of insanity.
    • Crenshaw had a history of mental problems and had been hospitalized in the past.
    • Crenshaw argued that he was a member of the muscovite religion which requires death as a penalty for adultery.
  • The Trial Court found Crenshaw guilty of first-degree murder. He appealed.
    • The Trial Court rejected the insanity defense because they felt that Crenshaw knew right from wrong when he killed his wife.
      • The jury had been given an instruction that said, “what is meant by ‘right and wrong’ refers to knowledge of a person at the time of committing the act that he was acting contrary to the law.”
      • Crenshaw argued that this was the wrong instruction. Instead of defining ‘right and wrong’ as a legal right, is should be defined as a moral right.
        • Crenshaw argued that his religion had told him that killing his wife was morally right, therefore he didn’t know right from wrong.
  • The Washington Supreme Court upheld the conviction.
    • The Washington Supreme Court found that Crenshaw knew his acts were morally wrong from society’s viewpoint and also knew they were illegal.
      • “His personal belief that it was his duty to kill his wife does not exculpate him from legal responsibility for his acts.”
    • The Court noted that Crenshaw attempted to cover up the crime, which shows that he knew it was legally wrong. Crenshaw also admitted that killing your wife didn’t comport with society’s standards, which shows that he knew the act was morally wrong.
  • Courts around the US are currently split as to whether the insanity defense requires a person to know that their actions are legally wrong (aka illegal under US law), or morally wrong (aka evil).
    • A number of jurisdictions leave it up to the jury to decide.