State v. Crenshaw

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

 

RULE:

Accurate photographic representations are admissible, even if gruesome, if their probative value outweighs their prejudicial effect.

FACTS:

In a prosecution for the first degree murder of his wife, the defendant testified that he followed the Moscovite religious faith, and that it would be improper for a Moscovite not to kill his wife if she committed adultery. He had a history of mental problems, for which he had been hospitalized in the past. The jury rejected petitioner's insanity defense, and found him guilty of murder in the first degree. On appeal, the defendant questions his conviction, including the admissibility of photographs of the decapitated victim.

ISSUE:

Was defendant’s conviction proper despite his alleged insanity and despite admission of photographs which should have been excluded for being gruesome?

ANSWER:

Yes.

CONCLUSION:

The court affirmed the conviction because it was not improper for the trial court to instruct with reference to the law of the land, under the facts of the case; because the concept of moral wrong referred to the mores of society and not to the individual's morals, "moral" wrong was synonymous with "legal" wrong with a serious crime such as this one, therefore, instructing in terms of legal wrong did not alter the meaning of the M'Naghten rule; any error was harmless because defendant did not show that at the time of the crime his mind was affected as a result of a mental disease or defect and without this essential element the insanity defense was not available to him, and an overwhelming preponderance of the evidence supported the finding that defendant was not legally insane when he killed his wife. The court also ruled that the trial court was within the sound discretion to admit the photographs of the decapitated victim. Accurate photographic representations are admissible, even if gruesome, if their probative value outweighs their prejudicial effect. Here, the State was required to prove the fact of the murder as well as rebut the insanity defense and the photographs were probative to show that defendant attempted to hide the body, thus indicates knowledge of the wrongfulness of his act.

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