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Law School Case Brief

State v. White - 60 Wash. 2d 551, 374 P.2d 942 (1962)


The insanity defense is available only to those persons who have lost contact with reality so completely that they are beyond any of the influences of the criminal law.


Defendant Don Anthony White was charged, by information, with committing two murders alleged to have been committed at different times and places on Dec. 24, 1959. He pleaded not guilty to both crimes by reason of mental irresponsibility. In a murder trial in Washington state court, the trial court instructed the jury that it could acquit defendant upon his plea of insanity only if it determined that he was unable to perceive the moral qualities of the act with which he was charged and was unable to tell right from wrong with reference to the act charged (the M'Naghten rule). The jury convicted defendant of murder and he appealed.


Was defendant's conviction proper?




The court affirmed the judgment of the trial court, which convicted defendant of murder. The court first held that the defendant's Fifth Amendment rights were not violated by the surreptitious recording of a confession because the Fifth Amendment did not apply to state action. The court also held that evidence supported the finding of premeditation necessary for the first-degree murder conviction because premeditation for only a moment was sufficient. The trial court had properly refused to play a tape made by a psychiatrist who interviewed defendant because the psychiatrist was allowed to give his opinion as to defendant's mental condition based upon the examination and the tape might have been subject to misinterpretation or misuse by the jury. Finally, the court provided an extensive review of the various insanity standards. The court rejected defendant's proposed instruction that would have permitted the jury to find defendant not criminally responsible if he lacked substantial capacity to appreciate the criminality of his act or to conform his conduct to the requirements of law. The court noted that the legislature had indicated that the insanity defense should be restricted to constitutional requirements, which were embodied in the M'Naghten rule.

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