Clark v. Arizona

Facts

In the early hours of June 21, 2000, Officer Jeffrey Moritz of the Flagstaff Police, in uniform, responded to complaints about a pickup truck with loud music blaring that was circling a residential block. He turned on the emergency lights and siren of his marked patrol car, and Eric Clark, the truck's 17-year-old driver, pulled over. The officer told Clark to stay where he was. Less than a minute later, Clark shot the officer, who died soon after. Clark ran away but was arrested later that day with gunpowder residue on his hands, and the gun was found nearby. Arizona charged him with first-degree murder for intentionally or knowingly killing a law enforcement officer in the line of duty. Clark did not contest the shooting. He relied on his undisputed paranoid schizophrenia to deny that he intended to shoot a police officer or knew he was doing so. The State offered circumstantial evidence that he knew the victim was an officer, and testimony that he had lured an officer to the scene to kill him. Clark's witnesses described delusions that Flagstaff was full of "aliens" who were trying to kill him and that bullets were the only way to stop them. A defense psychiatrist testified that Clark was insane at the time of the killing. The State's psychiatrist said the illness did not keep Clark from appreciating that his conduct was wrong.

Issues

1. Does due process prohibit Arizona from defining insanity solely as the incapacity to know that a criminal act was wrong, after the legislature dropped the cognitive-incapacity part of the older M'Naghten test?
2. Does due process prohibit Arizona from limiting evidence of mental disease and incapacity to its bearing on the insanity defense, so that it cannot be used directly to rebut the mens rea element of the crime?

Holding

Arizona's insanity test, which asks only whether the defendant did not know the criminal act was wrong, does not violate due process. Neither does the Mott rule, which channels mental-disease and capacity evidence to the insanity defense. The Court did not reach any claim about observation evidence, which it found was not properly raised.