The Washington Supreme Court held prospectively in State v. Crenshaw that a trial court should not include in its jury instruction a definition of “wrong” under the M’Naghten test for insanity in a criminal case. However, the court held that it was not reversible error in this case for the trial court to have defined wrong as “legal” wrong when instructing the jury. This decision appears to restrict the insanity defense, but fails to clarify what an accused must prove to be successful in asserting the defense.
Rodney and Karen Crenshaw were married on August 10, 1978 and went to Canada. Shortly after arriving in Canada, Crenshaw was deported because of a barroom fight. He rented a motel room in Blaine, Washington, where he waited for his wife. When Crenshaw’s wife joined him on August 27th, he thought she had been unfaithful. Crenshaw professed to be a member of the Moscovite religion and he believed that as a member he had a duty to kill an unfaithful wife. After beating her unconscious, he stabbed her twenty-four times, borrowed an ax and decapitated her. He meticulously cleaned the motel room and left his wife’s body in thick brush about 25 miles away. Later, Crenshaw picked up two hitch- ikers and told them of his act. After helping him get rid of his wife’s car, the hitchikers informed the police, and Crenshaw voluntarily confessed.
The jury found Crenshaw not insane.
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