Clark v. Arizona, 548 U.S. 735 (2006), is a United States Supreme Court case in which the Court upheld the constitutionality of the insanity defense used by Arizona.
Clark v. Arizona
Seal of the United States Supreme Court
Supreme Court of the United States
Argued April 19, 2006
Decided June 29, 2006
Full case name
Eric Michael Clark v. State of Arizona
Docket no.
05-5966
Citations
548 U.S. 735 (more)
126 S. Ct. 2709; 165 L. Ed. 2d 842
Case history
Prior
Defendant convicted, Coconino County Superior Court, Sept. 3, 2003; affirmed, Ariz. Ct. App., Jan. 25, 2005; review denied, Ariz., May 25, 2005; cert. granted, 126 S. Ct. 797 (2005).
Holding
Due process does not prohibit Arizona's use of an insanity test stated solely in terms of the capacity to tell whether an act charged as a crime was right or wrong. The state could also constitutionally limit a defendant's evidence of mental defect to only what is relevant to that insanity test, even when mens rea is an element of the charged crime. Arizona Court of Appeals affirmed.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens · Antonin Scalia
Anthony Kennedy · David Souter
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Case opinions
Majority
Souter, joined by Roberts, Scalia, Thomas, Alito; Breyer except parts III-B, III-C, and ultimate disposition
Concur/dissent
Breyer
Dissent
Kennedy, joined by Stevens, Ginsburg
Laws applied
U.S. Const. amend. XIV; Ariz. Rev. Stat. § 13-502(A)
The Court affirmed the murder conviction of a man with paranoid schizophrenia for killing a police officer.
The man had argued that his inability to understand the nature of his acts at the time that they were committed should be a sufficient basis for showing that he lacked the requisite mental state required as an element of the charged crime.
The Court upheld Arizona's restriction of admissible mental health evidence only to the issue of insanity and not to show that the defendant did not possess the required mental intent level necessary to satisfy an element of the crime. Evidence is admissible only to show that the defendant was insane at the time of the crime's commission.
In this case, the defendant knew right from wrong and so he could not qualify under Arizona's insanity defense.
