State v. Johnson

121 R.I. 254, 399 A.2d 469 (1979)

 

RULE:

A person is not responsible for criminal conduct if at the time of such conduct, as a result of mental disease or defect, his capacity either to appreciate the wrongfulness of his conduct or to conform his conduct to the requirements of law is so substantially impaired that he cannot justly be held responsible. The terms "mental disease or defect" do not include an abnormality manifested only by repeated criminal or otherwise antisocial conduct.

FACTS:

The defendant was convicted of a crime. On appeal, the defendant challenged the state's standard for determining the criminal responsibility for those who claim they are blameless because of mental illness. The court reviewed the state's standard, which was based on the M'Naghten test. The M'Naghten test considered whether a defendant knew right from wrong. The trial court's decision was reversed and the case was remanded for a new trial.

 

ISSUE:

Should the court abandon the M'Naghten test in favor of a new standard for determining the criminal responsibility of those who claim they are blameless by reason of mental illness?

ANSWER:

Yes.

CONCLUSION:

The court overruled the M'Naghten test, and ruled that a defendant would not be responsible for criminal conduct if at the time of such conduct, as a result of mental disease or defect, his capacity either to appreciate the wrongfulness of his conduct or to conform his conduct to the requirements of law was so substantially impaired that he could not justly be held responsible.

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